Burdensome Regulations: Examining the Impact of EPA Regulations on Main Street (House Small Business Committee hearing, February 14, 2024)

Summary

Transcript of the House Committee on Small Business hearing Burdensome Regulations: Examining the Impact of EPA Regulations on Main Street, convened February 14, 2024 during the 118th Congress, Second Session, published as Small Business Committee Document Number 118-040 (GPO 54-743). Chairman Roger Williams and Ranking Member Nydia Velázquez delivered opening statements. Witnesses were Brandon Farris of the National Association of Manufacturers, Cye Cooper Wagner of Cooper Oil and Gas for the Texas Alliance of Energy Producers, Dr. Lishan Aklog of PAVmed, Inc., and Michael Green of the American Sustainable Business Network. The appendix includes CRS and GAO reports on the Crain and Crain regulatory cost studies, submissions from the American Chemistry Council, Job Creators Network and Dr. Lemir Teron, and state and local chamber sign-ons.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Text recognized from a scanned document; may contain errors. Pages 651, 655, 657, 669, and 670 of 812 are not shown because the text could not be recognized reliably.

BURDENSOME REGULATIONS: EXAMINING THE
IMPACT OF EPA REGULATIONS ON MAIN STREET

HEARING

BEFORE THE

COMMITTEE ON SMALL BUSINESS
UNITED STATES
HOUSE OF REPRESENTATIVES

ONE HUNDRED EIGHTEENTH CONGRESS
SECOND SESSION

HEARING HELD
FEBRUARY 14, 2024

Small Business Committee Document Number 118-040
Available via the GPO Website: www.govinfo.gov
BURDENSOME REGULATIONS: EXAMINING THE IMPACT OF EPA
REGULATIONS ON MAIN STREET
BURDENSOME REGULATIONS: EXAMINING THE
IMPACT OF EPA REGULATIONS ON MAIN STREET

HEARING

BEFORE THE

COMMITTEE ON SMALL BUSINESS
UNITED STATES
HOUSE OF REPRESENTATIVES

ONE HUNDRED EIGHTEENTH CONGRESS
SECOND SESSION

HEARING HELD
FEBRUARY 14, 2024

Small Business Committee Document Number 118-040
Available via the GPO Website: www.govinfo.gov

U.S. GOVERNMENT PUBLISHING OFFICE
54-743 WASHINGTON : 2024
HOUSE COMMITTEE ON SMALL BUSINESS

ROGER WILLIAMS, Texas, Chairman
BLAINE LUETKEMEYER, Missouri
PETE STAUBER, Minnesota
DAN MEUSER, Pennsylvania
BETH VAN DUYNE, Texas
MARIA SALAZAR, Florida
TRACEY MANN, Kansas
JAKE ELLZEY, Texas
MARC MOLINARO, New York
MARK ALFORD, Missouri
ELI CRANE, Arizona
AARON BEAN, Florida
WESLEY HUNT, Texas
NICK LALOTA, New York
CELESTE MALOY, Utah
NYDIA VELAZQUEZ, New York, Ranking Member
JARED GOLDEN, Maine
KWEISI MFUME, Maryland
DEAN PHILLIPS, Minnesota
GREG LANDSMAN, Ohio
MARIE GLUESENKAMP PEREZ, Washington
SHRI THANEDAR, Michigan
MORGAN MCGARVEY, Kentucky
HILLARY SCHOLTEN, Michigan
JUDY CHU, California
SHARICE DAVIDS, Kansas
CHRIS PAPPAS, New Hampshire

BEN JOHNSON, Majority Staff Director
MELISSA JUNG, Minority Staff Director

(II)
CONTENTS

OPENING STATEMENTS

Hon. Roger Williams ....
Hon. Nydia Velazquez

WITNESSES

Mr. Brandon Farris, Vice President, Domestic Economic Policy, National As-
sociation of Manufacturers, Washington, DC, testifying on behalf of Na-
tional Association of Manufacturers .......ccccccscccssccessceseeeesseeeseenseeesaeceseceneeenseeesaes 5

Ms. Cye Cooper Wagner, Executive Vice President, Exploration, Cooper Oil
and Gas, Fort Worth, TX, testifying on behalf of Texas Alliance of Energy

Dr. Lishan Aklog, MD, Chairman & Chief Executive Officer, PAVmed, Inc.,
New York, NY ou.cccccccccccccccsscccssssccecsssccessseceesssecessseecesseeeceseeccesseeceesseecesseeseeseeeeeses 8
Mr. Michael Green, Director of Climate and Energy Policy, American Sustain-
able Business Network, Woodstock, VT uu.....eccccccccssessssesseeeeseeeseeesaeceseeenseenseeeaes 10
APPENDIX

Prepared Statements:
Mr. Brandon Farris, Vice President, Domestic Economic Policy, National
Association of Manufacturers, Washington, DC, testifying on behalf
of National Association of Manufacturers ..........cccccccccscceseeeseceeseeeseeeeseenseees 33
Ms. Cye Cooper Wagner, Executive Vice President, Exploration, Cooper
Oil and Gas, Fort Worth, TX, testifying on behalf of Texas Alliance

Of Energy Producers ........cccccssccsssesssesssseseseceseceeecesceeseeceseceseceseeeeeceseeeeseeeseees Al
Dr. Lishan Aklog, MD, Chairman & Chief Executive Officer, PAVmed,

Inc., New York, NY ..ccccccccccccccsssccessscccessseceeseecessseceeesseccesseecessseecesseeeeessaeeeenes 48
Mr. Michael Green, Director of Climate and Energy Policy, American

Sustainable Business Network, Woodstock, VT o....cccccccscccssseeseeeeeeeeeeeeees 54

Questions for the Record:

None.
Answers for the Record:

None.
Additional Material for the Record:

American Sustainable Business Network submitted by Michael Green ...... 63
American Chemistry Council (ACC) occeeccccccccssccessesseceeeeeeeeeeseeeseeesseeeeneeee
Comments from Texas Legislature ..............0
2011 CRS Report on Crain and Crain Study
2016 CRS Report on Crain and Crain Study
July 2014 Report GAO Report on Office of Advocacy, Crain and Crain ...... 727
Job Creators Network (SCN) o.cececcsccssesseeeseeseceseeseceeceseceeeeseceeceseceeeeeeeeeeaeeeees 778
Lemir Teron, PhD, Associate Professor, Howard University, Department

of Earth, Environment & Equity oo... cicecesceccesesseceseeeeceeeseceeeseeeeeeaeeeeeeaeees 781
Letters signed by 40 Members ou.....cccccccccssscssssesseeeseeceseceeeeceeeeeeeceeeenseenseeeeaes 784
National Mining Association (NMA) ......cceceseeccsseceeeeseeeeceseeeeeeseeaeeeeeeaeeeneeaeees 794
Natural Gas Vehicles for America (NGVAmerica) .......ccccececeeeseeeseeeteeeteeeenes 797

U.S. Chamber of Commerce o.........ccccccesssccesssscceesscccesceccessseccesseeceesseeceeaeeeesaaees 799

(IID)
BURDENSOME REGULATIONS: EXAMINING
THE IMPACT OF EPA REGULATIONS ON
MAIN STREET

WEDNESDAY, FEBRUARY 14, 2024

HOUSE OF REPRESENTATIVES,
COMMITTEE ON SMALL BUSINESS,
Washington, DC.

The Committee met, pursuant to call, at 10:00 a.m., in Room
2360, Rayburn House Office Building, Hon. Roger Williams [chair-
man of the Committee] presiding.

Present: Representatives Williams, Luetkemeyer, Stauber,
Meuser, Van Duyne, Salazar, Mann, Ellzey, Molinaro, Alford,
Crane, Bean, Hunt, LaLota, Maloy, Velazquez, Golden, McGarvey,
Gluesenkamp Perez, Scholten, Thanedar, and Davids.

Chairman WILLIAMS. The Committee will come to order. With-
out objection, the Chair is authorized to declare a recess of the
Committee at any time.

I now recognize myself for my opening statement.

Welcome to today’s hearing, which will focus on examining the
impact of burdensome EPA regulations on main street. I would like
to start off by thanking our witnesses for joining us today. You all
have traveled a long way to be with us this morning, and we appre-
ciate your attendance and appreciate your input.

When I travel around and speak to small businesses, I hear all
the time how the cost of everything is so high. From the price of
utilities to their labor costs, businesses feel like they are struggling
to get ahead. Unfortunately, there is another new aspect that has
made their operations even more challenging over the last 3 years,
and that is the increased cost of complying with regulations.

Most small businesses do not have a team of lawyers or a compli-
ance department to look through all the new mandates coming out
of Washington, D.C. Figuring out what needs to be done in order
to comply takes time away from the employees or owner that could
be better spent looking for growth opportunities or doing other rev-
enue-generating activities.

Now, while there are laws on the books that are supposed to pro-
tect small businesses from the worst of these regulations, they
seem to be failing. Since President Biden was sworn into office, his
administration has issued 766 final rules costing over $450 billion
to Main Street America. This type of overregulation has real world
consequences on American small businesses.

Of all the agencies creating the increased burden on Main Street
America, it is the EPA and has been one of the worst offenders.

(1)
2

This agency has taken a radical approach of environmental extre-
mism over practical policies to promote the environment. Some of
the EPA’s rules, which we will examine in more detail today, would
have drastic impacts in a variety of different industries throughout
our country. In some of the most extreme examples, entire indus-
tries would be regulated out of existence. This Agency takes a
heavy-handed government approach to force change, rather than
letting free markets and businesses make their own decisions.

And additional unintended consequence of these overbearing
EPA regulations is that not only do they harm America’s busi-
nesses, but they also put us at a competitive disadvantage with our
adversaries, like China. For example, the EPA is determined to
force a transition to clean alternatives by regulating coal, oil, and
gas companies into oblivion, thus making their product more ex-
pensive and less competitive in the market. Meanwhile, China’s fo-
cused on building whatever types of power plants are needed to
satisfy their demand.

And outside of being the voice for main street and Congress, this
Committee’s top priority is to hold agencies accountable for impacts
of rules and regulations on Main Street America. We have sent five
oversight letters to the EPA sounding the alarm on the negative
impacts of their rules. And unfortunately, many of their responses
are untimely and all of them are lacking in sufficient detail.

So, to ensure main street can thrive, our agencies need to listen
to small businesses during the rulemaking process. After all, the
government should be in the business of working for the people,
not against the people. And entrepreneurs have all endured signifi-
cant challenges over the past few years, and I hope this hearing
spotlights where the EPA has gone wrong and more importantly,
what can we do to fix it?

So lastly, I ask unanimous consent to submit documents for the
record for the American Chemistry Council and the National Sand-
stone and Gravel Association. Without objection, so ordered.

So thank you again for all of the witnesses being here today. I
am very much looking forward to our conversation.

And with that, I yield to our distinguished Ranking Member, Ms.
Velazquez, from the great State of New York.

Ms. VELAZQUEZ. Thank you, Mr. Chairman, and thank you to
all the witnesses for being here today.

The hearing we are holding today will focus on the impact of
EPA’s rules on small businesses. It is the third hearing in a series
on regulation. While we have heard that complying with federal,
state, and local rules can be onerous for small business owners, we
also heard that smart, well-crafted regulations can level the play-
ing field and help small businesses compete against larger corpora-
tions.

Most importantly, small businesses want their voices to be heard
during the rulemaking process, and they need compliance assist-
ance. That is why Congress enacted the Regulatory Flexibility Act
and established the Office of Advocacy and the National Ombuds-
man. The role of advocacy is to monitor the rule-writing process
and ensure agencies listens to the concerns of small businesses.
The role of the National Ombudsman is to assist with excessive
regulatory issues.
3

They also make sure that agencies offer small businesses timely
compliance assistance materials. It is important to note that both
of these offices gave the Environmental Protection Agency an A for
their compliance with the Regulatory Flexibility Act.

We can all agree that regulations are vital to Americans and
small businesses. EPA’s rules safeguard our nation’s air, lands, and
waters, and they yield more benefits for Americans than any other
agency. In fact, the benefits outweighed the cost by a ratio of 13-
to-1.

However, we may hear claims today that EPA is running amok
and the regulations stifle the growth of small businesses. I dis-
agree.

First and foremost, the agency is carrying out our laws, the laws
that Congress passed. The EPA has to operate within the statutory
guidelines, involve public participation, respond to comments, en-
sure the benefits, justify the costs, and follow the procedural re-
quirements of the Administrative Procedures Act and RFA. Put
simply, there is no overreach. The EPA is doing what Congress
asked them to do.

Secondly, between the passage of the Clean Air Act and 2022, air
pollution dropped by 78 percent and the economy grew. Smart,
well-crafted regulation can spur innovation and the development of
new clean technologies.

New opportunities abound for entrepreneurs to produce mate-
rials in cleaner ways. We cannot get stuck on the message that reg-
ulations hinder the growth of small businesses. We must look to
the future and understand that regulations can drive innovation
and grow the economy and protect public health and our environ-
ment at the same time.

I would like to enter into the record testimony from Dr. Lemir
Teron. Dr. Teron aptly points out the consequences of environ-
mental pollution and their contribution to a long history of environ-
mental racism and inequality. Research has shown that large pol-
luting facilities expose frontline communities made up of African
American and other socially and economically disadvantaged
groups to their dangerous levels of pollution. This aspect cannot be
overlooked in our discussion today, particularly for small busi-
nesses in this community.

With that, I look forward to hearing from the witnesses today
about EPA’s rule and hearing more about their experiences with
the agency, the Office of Advocacy, and the National Ombudsman
Office. It is important to know what we can do better to help you
succeed.

Thank you, Mr. Chairman. I yield back.

Chairman WILLIAMS. The Ranking Member yields back. I now
will introduce our witnesses.

Our first witness here with us today is Mr. Brandon Farris. Mr.
Farris is the vice president of domestic economic policy for the Na-
tional Association of Manufacturers, also known as NAM, located
here in Washington D.C. Prior to joining NAM, Mr. Farris was the
head of federal government regulations for The Chemours Com-
pany, where he played an integral role in the passage of the AIM

ct.
4

After serving in the Marine Corps Reserves, thank you for that,
he began his career in Washington as Bryce Harlow Foundation
Fellow at the George Washington University School of Law, while
working on the U.S. House Agricultural Committee.

Mr. Farris attended the Virginia Military Institute where he
earned his bachelor of arts in history and philosophy before attend-
ing the Johns Hopkins University where he received his master of
arts in government. He also holds a JD from the George Wash-
ington University Law School.

I want to thank you for joining us today and look forward to con-
versing.

Our next witness here with us today is Ms. Cye Cooper Wagner.
Ms. Wagner is the vice president of exploration, Cooper Oil and
Gas, located in the great city of Fort Worth, Texas. And Ms. Wag-
ner has been with the Cooper Oil and Gas since 2009, where she
serves in an executive management role over exploration regu-
latory departments, among others.

She has over 10 years of regulatory management working with
the Texas Railroad Commission, Environmental Protection Agency,
and the Texas Commission on Environmental Quality. Ms. Wagner
recently completed a 2-year term as Chairman of the Board of Di-
rectors for the Texas Alliance of Energy Producers, becoming the
first female and youngest serving Chairman of the Board in his 92-
year history.

Ms. Wagner attended Texas A&M University, where she earned
her bachelor of science in petroleum engineering.

It is great to have you in Washington, and thank you and we
look forward to our hearing together.

Our next witness here with us today is Dr. Lashan Aklog. Dr.
Aklog is the Chairman and CEO of PAVmed Inc., located in New
York City. PAVmed Inc. is a commercial stage medical technology
company cofounded by Dr. Aklog. He previously co founded a
medtech holding company, which founded four medical device com-
panies and led one of its portfolio companies, which commercialized
one of his lifesaving inventions.

Prior to entering the life sciences industry as an entrepreneur
and executive, Dr. Aklog had a career in cardiac surgery, serving
on the faculty of academic medical centers, including Harvard Med-
ical School. He was recognized as America’s top doctor for over a
decade. So it is really good to have you here today. All right.

So Dr. Aklog received his undergraduate degree in physics from
Harvard University and his M.D. from Harvard Medical School.

Thank you for joining us today, Doctor. We look forward to the
conversation that we have ahead of us.

And I now recognize the Ranking Member from New York, Ms.
Velazquez, to briefly introduce our last witness appearing before us

Ms. VELAZQUEZ. Thank you. It is my pleasure to introduce Mr.
Michael Green, who leads American Sustainable Business Network
Climate and Energy Working Group. Mike is passionate about en-
vironmental change and new innovative opportunities for small
businesses. His passion shines through his work. President Obama
recognized this commitment and presented Mike with the Cham-
pion of Change Award for his contribution to climate change.
5

Welcome. I look forward to your testimony.

Chairman WILLIAMS. Thank you. And again, thanks for all of
you being here today. We appreciate it.

Now, before I recognize the witnesses, I want to remind them
that their oral testimony is restricted to 5 minutes in length. That
is a big deal here, 5 minutes. Okay? And if you see the light turn
red in front of you, it means that your 5 minutes has concluded
and you should wrap up your testimony.

Now, if you hear this, you are going over and you need to stop
and listen to the gavel. Okay? The gavel is important.

I now recognize Mr. Farris for your 5-minute opening remarks.

STATEMENTS OF MR. BRANDON FARRIS, VICE PRESIDENT, DO-
MESTIC ECONOMIC POLICY, NATIONAL ASSOCIATION OF
MANUFACTURERS; MS. CYE COOPER WAGNER, EXECUTIVE
VICE PRESIDENT, EXPLORATION, COOPER OIL AND GAS; DR.
LISHAN AKLOG, MD, CHAIRMAN & CHIEF EXECUTIVE OFFI-
CER, PAVMED, INC.; AND MR. MICHAEL GREEN, DIRECTOR
OF CLIMATE AND ENERGY POLICY, AMERICAN SUSTAIN-
ABLE BUSINESS NETWORK

STATEMENT OF BRANDON FARRIS, VICE PRESIDENT, DOMES-
TIC ECONOMIC POLICY, NATIONAL ASSOCIATION OF MANU-
FACTURERS

Mr. FARRIS. Good morning. Chairman Williams, Ranking Mem-
ber Velazquez, Members of the Committee, thank you for the
chance to speak with you on behalf of the 13 million people who
make things in America to convey the urgency of halting the regu-
latory onslaught.

Small businesses are essential for our economy. They account for
44 percent of U.S. economic activity. In the manufacturing sector,
the majority of firms are small and function as the backbone of the
manufacturing supply chain. Yet manufacturing is facing signifi-
cant headwinds in the form of the cost, complexity, and uncertainty
associated with a new wave of overreaching and burdensome fed-
eral regulations.

The NAM commissioned a study which found that the total cost
of federal regulations is over $3 trillion, an amount equal to 12 per-
cent of our GDP. The average U.S. company pays approximately
$13,000 per employee per year to comply with federal regulations,
yet the burden is substantially higher for manufacturers, especially
small ones. U.S. manufacturers with fewer than 50 employees
incur regulatory compliance costs of an estimated $50,000 per em-
ployee per year. This is more than three times the cost borne by
the average U.S. company, money that would be much better spent
investing in new machinery, hiring more workers, or developing
new and innovative products.

The NAM analysis only reflects regulations in place as of 2022,
but new proposed regulations have been especially disruptive and
will further chill manufacturing growth. For example, the EPA re-
cently finalized an early reconsideration of the particulate matter
air quality standards. These revised standards will create permit-
ting gridlock throughout the country as permit applicants will have
to model the new standard within 60 days. It leaves little room for
6

industrial activity, as EPA itself concedes that as much as 70 per-
cent of particulate matter comes from non manufacturing sources.

Ultimately, states are going to have to ration which new invest-
ments should be allowed to break ground to avoid falling into non-
attainment. Needless to say, this regulation will cut manufacturing
investment directly and potentially drive cutting-edge factories to
other nations with less onerous standards.

This is just one example of an Agency action that will have far
reaching effects across the manufacturing economy. Many other
proposals are moving forward towards finalization.

The EPA has just proposed a burdensome reporting requirements
and actions that will restrict or create de facto bans on PFAS pro-
duction or use. The issue is that for many of the current uses,
semiconductors, EV batteries, medical devices, items for national
defense, there are no existing replacements for PFAS. These pro-
posed restrictions would force manufacturers to abandon domestic
production of critical items and instead rely on foreign production.

Another proposed EPA regulation would impose new require-
ments on natural gas and coal power plants, which account for
more than 60 percent of our total power generation. Noncompliant
facilities will be shut down.

In another instance, the EPA has proposed regulations at levels
so low it would create a de facto ban on the production and use of
ethylene oxide, which is used to sterilize medical devices, including
PPE used by doctors and hospitals.

The EPA has also proposed additional barriers to its review
under the TSCA program, which is critical to innovation. Under
TSCA, the EPA is mandated to review new chemical applications
within 90 days. However, the vast majority of these take much
longer, and the new requirements may further extend that ap-
proval period, delaying deployment of new, efficient products.

Small businesses are vital to our economy and our lives. If we
fail to reduce the regulatory burden on them, the U.S. is at risk
of threatening the spirit that has allowed small businesses to
thrive. On the other hand, if we reduce their burdens and their
cost, there is no limit to what small businesses can accomplish.

Thank you.

Chairman WILLIAMS. I recognize Ms. Wagner for her 5-minute
opening remarks.

STATEMENT OF CYE COOPER WAGNER, VICE PRESIDENT,
EXPLORATION, COOPER OIL AND GAS

Ms. WAGNER. Thank you, Mr. Chairman, Ranking Member, es-
teemed Members of the Committee. It is an honor to be able to
speak with you today.

Thank you, Mr. Chairman, for the introduction. And that is quite
enough about me. Let’s talk about my small business.

I am a second generation E&P operator. We are based in Fort
Worth, Texas, and the majority of our production is in north cen-
tral Texas, in rural areas where I grew up. I graduated from a high
school class of about 30 kids and went off down to Texas A&M and
got an engineering degree. And after working for some great es-
teemed, large independent companies and even a super major dur-
ing college, I landed back in Fort Worth with a small independent,
7

and then came knocking on my dad’s door for a job and I enjoy
being the second generation running that company, which I do now
with my husband and my brother. So, a true family business.

We employ 11 people full-time. We have about 20 contractors
that we hire on a month-to-month basis. And in addition, we, in
2023, sent 1099s to around 200 other contractors that the majority
of their payroll, you know, is Joe Smith, LLC. It is just Joe. He just
comes and does all of the roustabout work or another type of repair
work. His wife is a nurse in the local hospital. She comes in and
does the books at night.

We are the lifeblood of the small rural communities where I was
born and raised. We have a significant community impact as a
company. Not only do the taxes from our wells, the ad valorem
taxes, the property taxes, go straight to the rural hospitals, the
school district, and the local communities. But we are very active
members in the lifeblood that keeps these rural areas thriving.

We sponsor the county stock shows, the Little League teams, the
volunteer fire departments, because there is no full-time staffed
fire department in these rural areas. The towns are a size of 200
to a couple thousand people. We are one of the largest employer in
almost a four-county area to offer 401(k), health insurance, paid
leave. Our company is a vital piece of the micro economy of these
rural areas.

And while I am pleased to be here today to share what is prob-
ably a unique perspective, because not only am I a second genera-
tion E&P mom-and-pop oil and gas operator, I am a fifth genera-
tion farmer and rancher. So stewardship of natural resources is in
my veins. It runs through my blood.

I am a staunch supporter of clean air, clean water, and caring
for the lands on which we provide these natural resources to Amer-
ica. It is a message that I tell my kids daily. My two young chil-
dren are frequently riding around with my husband and I in rural
areas and on our ranch. And I say, this is how we farm this wheat
crop responsibly. This is how we raise these thousands of cattle, all
natural, with no steroids or antibiotics, and care for the water they
drink, the air that they breathe, and the land that they graze. This
is how we hunt, fish, and manage the game responsibly on this
property, and do so, so that we can continue to do that for genera-
tions to come. And these are the oil and gas wells that mommy and
daddy drilled right here in the middle of it where your great grand-
parents still live.

And I am not alone. While that may sound like a unique perspec-
tive from the oil and gas industry, I am just a small representation
of a very large swath of small to midsized operators, not only in
Texas, but when I was Chairman of the Board of the Texas Alli-
ance of Energy Producers, a 3,000 strong member organization in
Texas, I was able to meet folks from all over the country, from
Kansas, Illinois, New Mexico, Oklahoma, Louisiana, and learn they
share the same small business ethos and regulatory environments
that I have in Texas.

In that regulatory environment, I am mandated right now on ba-
sically three levels of regulation. We have state-mandated regula-
tion, federally delegated regulation to the state of Texas, and also
American Petroleum Institute standards for my equipment for safe-
8

ty and emissions. In 2023, in oil and gas friendly Texas, in 365
days in a calendar year, I was inspected 297 times. I passed all of
those inspections, some with reinspections. And that is up in aver-
age from 215 inspections on average per year from August 1 of
2015.

I am a proud member of a highly regulated industry. And within
those existing rules, the state of Texas has done great things. The
oil and gas industry has done great things. We have sextupled pro-
duction, meaning a sixfold increase of production, with the same or
lower greenhouse gas emissions than we have had since 2010.

We are stewards, not wasters. The wells I operate are very mar-
ginal. They make an equivalent of five barrels of oil a day. I do not
have room to waste in my business. I have to monitor every single
product that I produce because it is vital to be able to give the good
jobs and support the communities of which I live in.

The regulations on small business like mine provide certainty for
me, my employees, and the communities we support. I urge this
Committee to please know that if you do not allow my company to
continue to produce these viable in-demand products in the clean-
est and best ways that we do in the world, you will push these jobs
and this environment overseas where they don’t do it cleaner be-
cause they don’t have an EPA, an API, or a Texas Railroad Com-
mission.

Thank you so much.

Chairman WILLIAMS. The lady yields back. And I now recognize
Dr. Aklog for his 5-minute opening remarks.

STATEMENT OF DR. LISHAN AKLOG, MD, CHAIRMAN & CEO,
PAVMED, INC.

Dr. AKLOG. Good morning, Chairman Williams, Ranking Mem-
ber Velazquez, and Members of the Committee. Thank you for in-
viting me to testify today.

My name is Dr. Leshan Aklog. I am a heart surgeon, medical
technology innovator, and small company chief executive. Last
summer, I was honored to testify before the Subcommittee on
Health on Medicare Coverage of Innovative Medical Devices. My
testimony today focuses on upcoming EPA regulations on ethylene
oxide, which is used to sterilize billions of medical devices a year.

Although there is broad industry support for updated regula-
tions, EPA’s proposals are projected to greatly reduce sterilization
capacity and patient access to critical medical devices. I am here
to provide my perspective as a surgeon and small company chief
executive. I am not an expert on environmental science, toxicology,
sterilization technology, or even the deeper policy dimensions.

Most lifesaving medical innovation happens at small companies
such as mine. Government can have a significant positive impact
on patient access to our innovations. For example, SBIR and STTR
funding are a lifeline to early stage companies, and I commend the
House for reauthorizing these programs and for including innova-
tion, fostering R&D expensing provisions in the recent tax bill.

I was also pleased that H.R. 1691, the innovation-focused subject
of my testimony last summer made it out of Committee.

Today, however, we address a proposed government action with
a large potential negative impact, exposing millions of patients to
9

the risk of delayed care and even death. And I assure you that is
not hyperbole.

Sterilization lies at the heart of medical device manufacturing.
One of the most time-consuming and costly steps of the FDA clear-
ance process is sterilization validation. We must prove that the de-
vice possesses zero infectious risk to the patient and that steriliza-
tion does not damage or impair its function. This is more difficult
than it sounds. Sterilization using heat or radiation can damage in-
tricate components and can’t penetrate the inner parts of a complex
assembly. Ethylene oxide gas, however, can sterilize every inner
surface of a device without damaging its structure or function. It
is the only available technique to sterilize the majority of medical
devices.

Let me offer an example from my own experience as a heart sur-
geon. Nearly a million patients per year receive lifesaving artificial
heart valves. They are marvels of modern medical technology. Per-
fect sterilization is critical since artificial heart valve infection is
catastrophic and sometimes fatal. Ethylene oxide is the only avail-
able technique to sterilize an artificial heart valve.

A large percentage of heart valves are sterilized at a single U.S.
facility. The sudden closure of this facility, even temporarily, would
be devastating and many patients would die.

I also have experience with ethylene oxide sterilization as an en-
trepreneur and chief executive.

Our experience commercializing our EsoCheck device illustrates
the unique challenges small, innovative companies face with steri-
lization. EsoCheck is a deceptively simple tool which allows precise,
targeted collection of lower esophageal cells for precancer testing.
It is performed in a doctor’s office in less than 2 minutes without
anesthesia or sedation. A small balloon attached to a thin catheter
gently swabs cells from the target area, and a capsule protects the
sample as the catheter is withdrawn. EsoCheck’s gentle approach
to noninvasive cell collection is a dramatic and elegant improve-
ment over cruder, decades-old technology, which involves dragging
a Brillo pad-like sponge on a string indiscriminately scraping cells
from the stomach, esophagus, and mouth. It is a big advancement.

EsoCheck’s initial FDA clearance required ethylene oxide steri-
lization. Unlike large companies who can bring sterilization in
house, we are dependent on a small number of third party steriliza-
tion companies with limited capacity. We are the lowest priority
customers and as a result, experience serious supply challenges as
EsoCheck demand grew.

To mitigate supply chain risk from proposed EPA regulations, we
decided to deploy precious resources and successfully resubmitted
EsoCheck for FDA clearance as a nonsterile device.

The other products in our pipeline, however, must be delivered
and remain at severe risk if EPA regulations move forward as pro-
posed. Although, as I noted, I am not an ethylene oxide steriliza-
tion expert, I am a mainstream small company executive who is
deeply concerned that pending EPA regulations, if implemented as
proposed, will have a devastating effect on patient care.

I am also first and foremost a physician and recently lost a fam-
ily member to cancer. No one in this room is more committed than
I am to preventing cancer. Cancer prevention is the sole mission
10

of Lucid Diagnostics, which occupies the majority of my profes-
sional time.

As a first-generation American who fled political violence in Ethi-
opia, I have faith that this great country, which has given me
boundless opportunities, can apply technology and commonsense
solutions to address its challenges.

Let me be blunt, as surgeons are prone to be, updated EPA regu-
lations require the surgical precision of a scalpel. We can keep com-
munities safe without compromising patient access to critical de-
vices. I implore this Committee in Congress to urgently work with
the EPA, FDA, and the medical technology industry to get the up-
dated ethylene oxide regulations right. Patient access to critical
and lifesaving technologies depend on it. Thank you very much.

Chairman WILLIAMS. Thank you very much, Doctor.

And I now recognize Mr. Green for his 5-minute opening re-
marks.

STATEMENT OF MICHAEL GREEN, DIRECTOR, CLIMATE AND
ENERGY POLICY, AMERICAN SUSTAINABLE BUSINESS NET-
WORK

Mr. GREEN. Let me start by just saying happy Valentine’s Day.
Hopefully, you guys have a second to reach out to somebody that
you love or think about them.

Chairman Williams, Ranking Member Velazquez, and fellow
Members, I welcome the opportunity to engage with your Com-
mittee to discuss the nature of regulatory policies coming from the
EPA and their impact on main street businesses. I have the oppor-
tunity today to represent the American Sustainable Business Net-
work and our hundred of membered businesses, chambers of com-
merce, and affiliated groups spread across the country.

I also have the opportunity to speak to you from a unique per-
spective of owning a small business that is on my community’s
main street in Woodstock, Vermont. I would like to start with shar-
ing the experience of our community this past summer when a se-
ries of irregular weather caused our second 100-year flooding event
in the last 15 years. Between July 10 and 11, we had nine inches
of rainfall on the green mountain spine. The waters rushed down
in inundated towns across our state, causing widespread damage to
businesses, farms and homes. My family was fortunate to be spared
from the devastation experienced by my neighbor right next door
and many of the businesses in our community.

On the morning of the 11th, people woke up across the state to
complete destruction as several communities were completely cut
off from rescue services with roads sucked into the raging rapids.
In Woodstock this storm not only flooded our businesses, but it also
wiped out our town’s public water and drinking supply in what
should have been our busiest summer peak season.

This experience is not unique to Vermont. This is the same story
of small businesses across the country as we learn to adapt to cli-
mate change. We know that small businesses are disproportion-
ately impacted by the threats of climate change due to their limited
resources to absorb financial shocks from such catastrophic events.
A study by FEMA highlighted that 40 percent of the small busi-
nesses never reopen following such a disaster. This is caused by a
11

lack of ability to relocate our brick-and-mortar businesses, being
locked into less diversified supply chains, and an inability to com-
pete with large corporations in the global marketplace.

Businesses are not only feeling the impact of the climate crisis
through major flooding events, as many businesses are also forced
to shutter their doors because of extreme heat and poor air quality
over this past summer. The impacts of unchecked localized air pol-
lutants have an impact on our workforce as they exasperate these
issues and our customers and communities as a whole, as they are
either stuck inside at best or struggling to breathe from asthma
and acute pulmonary impacts of air pollution at worst. Strong EPA
regulations, such as the recent final rule on soot, play a critical role
in safeguarding public health and reducing pollution related ill-
nesses, lowering our health care costs for our small business com-
munity.

The EPA can also support main street businesses when they are
left powerless, facing the challenges outside their control. The Good
Neighbor plan is a great example of this, as a policy protects com-
panies from the pollution from faraway facilities that don’t mitigate
their downstream effects. It would be almost impossible for a main
street business to create these sort of protections in their own
state, let alone to do this in a neighboring state.

These are the threats that we should be focused on today, and
we should be discussing. For far too long, we have been fed by a
false narrative that environmental and public health regulation
hamper our economic growth. Experience shows the exact opposite
is true. EPA regulation and technical assistance grants open the
door for innovation and investment into otherwise antiquated, pol-
luting industry. This innovation creates jobs, aligns the market-
place with a healthier environment, and the opportunity for
growth.

EPA regulations have often been a catalyst for innovation, driv-
ing both large and small businesses to develop, adopt, and market
environmental-friendly technologies and practices. This has created
a wave across the country of clean technology, and it makes it one
of the fastest growing sectors in many of the states that have given
it the opportunity.

I would like to end my testimony today by challenging the
premise offered for our conversation. Main street businesses are
often the backbone of their local economy, especially in small towns
like mine. At the end of the day, we have to look at our neighbors
face to face. Main street business owners are often compelled to
pursue decisions based on what is right for their community as
they understand the delicate role for public health and environ-
ment play in their strong community fabric.

Plain and simple, we will choose stronger controls over putting
the local environment and public health at risk 10 out of 10 times
and side with the health and safety of future generations. This is
a different motive than the out of state, shareholder-controlled pol-
luting industries that are driven by no other motive than profit.

Time in today’s conversation would be best spent focusing on the
resources needed to align with large point source pollution
emitters, which I have never seen on a community’s main street in
the first place, with what is best for our public health and our envi-
12

ronment. I will continue to work with this Committee, as well as
with the EPA to ensure that small businesses are provided a seat
at the table and push for the strongest protections possible for our
environment, public health.

I welcome any questions. Thank you.

Chairman WILLIAMS. Great job. And before we get started, I
want to just say you will see Members moving in and out, coming,
and eventually everybody will have worked their way through here.
But don’t take it personal, okay? We have got a lot of Committees
going on today, so that is important to know that.

I now recognize myself for 5 minutes.

In some cases, the EPA is so aggressive that they look to regu-
late entire industries and rules out of existence. My family has
been in the automobile business for almost 89 years. I have been
in it 50 years. And we have never seen such an aggressive push
to regulate tailpipe emissions and force the transition to electric ve-

icles.

The problem with this is in Texas, there is no market, I repeat
no market, for electric vehicles. People are looking for a car or
truck that can pull a horse trailer or a boat hundreds of miles and
not have to be worried about finding a charging station and wait-
ing a long time for electric vehicles to get charged back up. And
the EPA doesn’t understand this. They just don’t. And they are try-
ing to force this transition on the market when the people simply
should decide they want it or not want it and let the product sell
on its own.

So the oil and gas industry is currently seeing similar hostilities,
I believe, from this agency. So, Ms. Wagner, can you elaborate on
the way the EPA treats the oil and gas industry compared to re-
newable energy companies? And what do you think the long-term
impacts of this forced transition will be?

Ms. WAGNER. Thank you, Mr. Chairman. The difference be-
tween a lot of what you see in the green industry and the renew-
able industry, to which I am very familiar with, on one of our
farms and ranches, we have wind turbines on a ranch of ours that
is in my family land. So I have seen what happens when the big
renewables come to the small towns and what they do and a big
push from the EPA and a lot of people that support more regula-
tion is that the jobs that will go away in my industry, because of
this duplicitous regulation that is coming.

Like I mentioned in my testimony, I am highly regulated al-
ready. I am a marginal well producer. I know what resources are
coming out at the wellhead and what I am selling. And if there is
a loss anywhere between those two points, I am looking at it before
any regulator because I cannot afford to have a leak, a spill, or
anything else. So these proposed regulations are onerous and would
cost the jobs in the community and the lifeblood in those small
towns.

And when the big green companies come in, it is a temporary job.
A lot of people, you hear the rhetoric that there are green jobs out
there for everyone that leaves the oil and gas industry because fos-
sil fuels are bad and they are all going away. Well, we need fossil
fuels. We need them for the medical products that the good doctor
has talked about here.
13

And those jobs did not come to our small town and stay. They
were temporary guys that came in. And the green companies that
come in have wonderful subsidies and grants and things that the
federal government has done for them that do not get reinvested
into Main Street USA. Very different than the oil and gas economy.

So while they are getting helped, we are getting hindered.

Chairman WILLIAMS. Thank you for that testimony.

Mr. Farris, it is estimated that U.S. small businesses spend over
$60 billion per year on electricity. As electricity rates increase for
consumers across the U.S., we must prioritize the importance of af-
fordable and reliable electricity access for small businesses.

So my question to you is, can you please speak to the cumulative
impact of EPA’s regulations targeting the energy sector on the elec-
tric bills of small businesses?

Mr. FARRIS. Thank you, Mr. Chairman, and absolutely. With
the EPA’s new power plants proposal, they are targeting 60-plus
percent of our power generation, and that is natural gas and that
is coal. And they have to, within 10 years, have widespread deploy-
ment of carbon capture and hydrogen. Both of those are wonderful
technologies, but they are not available at the scale needed for this.
And what will happen in those 10 years is that 60 percent of our
power generation will shut down. And so bills will go up trying to
meet these, but also we will have widespread power outages in the
U.S. because of that power generation shutting down. So it can
have a catastrophic effect on small businesses, Mr. Chairman.

Chairman WILLIAMS. Thank you. Dr. Aklog, I got about a
minute left to go here and I want to talk about ethylene. Is that
how you say it? Say it again. Ethylene oxide, right? Explain to the
Committee what banning the use of ethylene oxide would mean for
human health.

Dr. AKLOG. Well, it starts from the fact that there are 20 billion
medical devices sterilized by it with ethylene oxide in this country
a year, and that represents about one in two medical devices.
Ethylene oxide sterilized devices are everywhere in healthcare. You
step into a hospital, every corner has IV, syringes, you know, very
simple technologies, as well as the most complex technologies, such
as the heart valve that I described.

So a decline, a meaningful decline in capacity for sterilization
with ethylene oxide will lead to supply chain issues and patient ac-
cess to lifesaving medical technologies. And in some cases, where
they are urgent, where these procedures are urgent, it could lead
to severe patient suffering and death.

Chairman WILLIAMS. Okay, thank you. My time is up.

I now recognize the Ranking Member for 5 minutes of questions.

Ms. VELAZQUEZ. Thank you, Mr. Chairman.

Mr. Green, Americans want a livable planet, but some in Con-
gress believe there is a trade-off, either the environment or the
economy. Is this true?

Mr. GREEN. This shouldn’t be true, but that is their sense.

Ms. VELAZQUEZ. How are new, innovative technologies emerg-
ing from environmental regulations leading to new business starts?

Mr. GREEN. Yeah. So I have had the opportunity to spend some
time at an innovation space called Greentown Labs, which they
have an operation in Houston as well as an operation in Boston,
14

Massachusetts. They are growing, incubating, and supporting small
businesses that are revolutionizing clean technology. And guess
who is one of the largest supporters in embracing of these new
technologies, is the oil and gas industry. They look at this as an
opportunity to change their business models and start to innovate
and clean up in ways that are being less maybe facing the regula-
tion and more towards the opportunity of growth and looking for-
ward to a new American economy.

Ms. VELAZQUEZ. Mr. Green, the regulations written by the
EPA clean our nation’s air, land, and waters. In your testimony,
you mentioned that they can also level the playing field for small
businesses. Can you please expound on this aspect of your testi-
mony?

Mr. GREEN. Small businesses and main street businesses that
we work with don’t have the opportunity to use our air and water
as a dumping ground. And they often are at the feeling the impacts
of such decisions that are made by large corporations. So when lev-
eling the playing ground, all it is doing is it is holding the corpora-
tions to the same thing that a small business would probably de-
cide in the first place of supporting public health in their local en-
vironment. ,

Ms. VELAZQUEZ. Thank you. Dr. Aklog, the proposed rule
doesn’t ban EO, does it?

Dr. AKLOG. I don’t believe so. But as I mentioned, I am——

Ms. VELAZQUEZ. Correct. I support strong rules to protect pub-
lic health. I understand your concerns with the proposed rule, and
I really appreciate your testimony here today. I would like to know,
has the EPA worked with federal agencies and the private sector
to hear your concerns?

Dr. AKLOG. Yes. So, I serve on the board of AdvaMed. I am the
incoming Chair of the Excel division, which focuses on small com-
panies. And I have been invited to participate in discussions with
the EPA, with the administrator, with the deputy administrator,
mostly for my perspective, not on the policy side, but on the
healthcare side. And so those conversations have occurred. I know
FDA has weighed in. I believe the SBA has also weighed in. So
those conversations are happening.

And I think the important point is that industry supports up-
dated regulations. It is just the specific aspects of these rules are
not surgical. They have the potential to have an impact. And I be-
lieve there are sensible modifications that can achieve those goals
without having that adverse patient impact.

Ms. VELAZQUEZ. Thank you. Mr. Farris, you cite a 2023 Crane
& Crane report. I haven’t read the report, but I do know that in
2010, a study that was produced by Crane & Crane was criticized
by CRS and the Government Accountability Office, two inde-
pendent offices that work with Congress, as well as the Economic
Policy Institute for using unreliable methodology and flood data.
Were you aware of that?

Mr. FARRIS. We are aware that anytime there is an academic
study, there will be questions about the validity of the data. We
stand behind the Crane study and believe that is a valid snapshot
of the cost of regulation.
15

Ms. VELAZQUEZ. So do you believe that the Congressional Re-
search Office and the Government Accountability Office were
wrong in their assessment of the Crane & Crane report?

Mr. FARRIS. Yes, ma’am. We stand behind the Crane data.

Ms. VELAZQUEZ. Okay. Well, I questioned the data based on
the study and the opinion issued by our government agencies.

Mr. Green, Democrats delivered on two new laws: the Bipartisan
Infrastructure and Jobs Act and Inflation Reduction Act. How are
the regulations to carry out these laws helping small businesses to
grow and flourish?

Mr. GREEN. Thank you so much for the question. You know, in
small mountain communities and communities that are feeling the
impacts of climate change such as ours, we are looking for folks
down here in D.C. to pull every single lever you possibly can to
help us get on the right trajectory. So these regulations work hand-
in-hand with the innovation and the grant programs that are com-
ing out of the EPA, as well, to help businesses reach to compliance,
as well as to reach the innovation goals that we all have for a
healthy environment.

Ms. VELAZQUEZ. Thank you, Mr. Chairman. I yield back.
Thank you.

Mr. GREEN. Thank you.

Chairman WILLIAMS. The lady yields back.

I now recognize Representative Meuser from the great state of
Pennsylvania for 5 minutes.

Mr. MEUSER. Thank you very much, Mr. Chairman. And thank
you very much to our witnesses. Really appreciate it. It is very in-
teresting and highly informative.

So, as I think most of us know, inflation over the last 3 years
is up over or nearly 18 percent, 17.9 percent. We get CBO records
that show regulations on businesses in general are up since the
Biden administration has taken—went into effect, over $400 bil-
lion. Clearly, that adds to inflation.

Regulations do serve, clearly, a cost on your business, Ms. Wag-
ner, as you were pointing out. We also have a letter from the Small
Business Administration Office of Advocacy stating how on this
proposal, Clear Power Plan 2.0, that the EPA has significantly un-
derestimated the cost that its proposed rules would impose on
small entities.

I am interested in hearing, Mr. Green brought up that or the
question was do we have to forsake the environment for land devel-
opment, for manufacturing development, for the development of
medical devices that are life-saving?

I would like, Mr. Farris, I am going to start with you, A, tell me
what you think about that comment as well. You have how many
manufacturers that you represent?

Mr. FARRIS. Nearly 14,000.

Mr. MEUSER. Fourteen thousand. And how many of them are
small business?

Mr. FARRIS. The vast majority.

Mr. MEUSER. Okay, the vast majority. Number one, do you
think they would agree with that comment? And number two, has
the EPA come and spoken to you and asked how would this rule
affect those vast majority of 14,000 small businesses that create
16

the jobs that pay for the Little Leagues, that take care of—truly
are the ones invested in taking care of their communities’ environ-
ment?

Mr. FARRIS. Thank you, Congressman. And what I can say is
there doesn’t have to be a trade-off. Industry has worked, and we
have some of the cleanest air in the world. We have innovated, and
those technologies have led to having some of the cleanest air in
the world.

One of the great problems that we are seeing right now with
these regulations is that they are so close to zero that they are
unachievable. So, yes, there does not have to be a trade-off. We can
have clean air and we can have a wonderful economy, but we can-
not have it with these regulations that we are seeing right now.

And then to your point about is EPA hearing? Is EPA listening?
I differentiate hearing and listening. Yes, there are hearing ses-
sions where they hear concerns, but are they listening? What we
have seen on PFAS, what we have seen on ethylene oxide, is that
other agencies are weighing in with EPA and saying, if you create
a de facto ban on PFAS, we can’t make semiconductors in the U.S.,
and the EPA isn’t listening.

We have heard the same thing on ethylene oxide. If you create
a de facto ban on ethylene oxide, we will no longer be able to steri-
lize most medical equipment. And EPA isn’t listening, sir.

Mr. MEUSER. Thank you. Ms. Wagner, I am going to ask you
a question. So of all the regulations that you deal with, would you
say half have the type of effect that was intended on the environ-
ment and the other half are unnecessary costs? I don’t want to put
words in your mouth. You tell me what you think the outcomes are
of those regulations that obviously add a lot to your cost of doing
business.

Ms. WAGNER. Absolutely.

Mr. MEUSER. Which ones are worth it and which ones aren't.

Ms. WAGNER. In Texas, the regulations that we are functioning
under now that, like I said, my family business has been under and
in good standing with the Texas Railroad Commission for 40 years,
those regulations are prudent and just and necessary. They are
based on science, fact, common sense. There is a lot of boots on the
ground work to understand how these things work in the real
world.

There is understanding of the difference in a marginal well that
a producer like myself with a couple of hundred wells across the
state of Texas versus the super majors and millions of barrels a
day that they are moving. The economies of scale are taken into
consideration, the volumes, the pressures. There is a lot of science
to that.

So the regulations we have, like I said in my testimony, I think
both written and oral, I am a proud member, as many operators
are, of a highly regulated industry. We have a duty to protect and
steward the natural resources, not only the ones that we produce,
but the ones that we protect. The problem with the regulations
that are ambiguously being proposed right now, the ambiguity, par-
don me, is a huge part of the problem.
17

And the rest of that is we are doing it. We are stewards. We are
doing it now. So now it is just duplicitous and punitive and it is
not going to help the environment.

Mr. MEUSER. Thank you very, very much.

Ms. WAGNER. Sure thing.

Mr. MEUSER. Question to you, Doctor. Do you think there is a
more realistic and effective way in which the EPA could implement
this rule that would not be detrimental, that could actually be posi-
tive to you?

Dr. AKLOG. My understanding is there are engagements and
there are alternatives really focused around the time to implemen-
tation and the flexibilities that we have.

Mr. MEUSER. I apologize, sir.

Dr. AKLOG. Thank you.

Mr. MEUSER. I didn’t leave you enough time to respond.

I yield back, Mr. Chairman.

Chairman WILLIAMS. The gentleman yields back.

I now recognize Ms. Scholten from the great state of Michigan
for 5 minutes.

Ms. SCHOLTEN. Fantastic. Thank you so much, Mr. Chair, and
thank you to our witnesses. I am up a little earlier in my order
than I thought I would be, so I am going to jump right in here.

This is the third regulatory oversight hearing that we have had,
and I really look forward to hearing how smart, well-crafted regula-
tions help level the playing field for small businesses throughout
America. To that end, it is important to recognize when it comes
to the EPA that the Agency is carrying out the laws passed by Con-
gress using science and leveraging the latest technologies available.

My first question is for you, Mr. Green. Cutting through the
rhetoric that compliance with commonsense environmental protec-
tions stifles opportunities for small businesses to grow and operate,
to what end is the impact of these regulations measurable economi-
cally? Can we safely say that the benefits outweigh the costs of the
regulations or vice versa?

Mr. GREEN. We absolutely can. It is 30-to-1, $30 to gained to
our economy for $1 spent in the regulation.
vis. SCHOLTEN. Fantastic. I am not going to argue with you
there.

As the effects of climate change hit more and more doorsteps
across the country, it is clear that Main Street America has to
adapt. That being said, it is not easy to say what we can reason-
ably expect small businesses to do on their own while remaining
solvent and, in some cases, quite literally above water. We also
know not all small businesses are created the same, right, ranging
in scale from a couple dozen to a couple hundred.

This question, again, is for Mr. Green. In your testimony, you
highlight ways environmental regulations help to level the playing
field for small businesses. Can you also speak to their impact on
markets and any new and innovative strategies that they may
produce?

Mr. GREEN. Yeah. No, they absolutely create the opportunity to
move markets and create new products for consumers that I think
there is a strong demand. As an electric vehicle driver in a rural
community, my family has taken advantage of such amazing pro-
18

grams. And I was really pleased when I took the opportunity to
look up Roger Williams Chrysler, Jeep, and Dodge, and at the very
first top of the menu was how to purchase an electric vehicle.

And so we are already seeing a lot of consumer interest and con-
sumer demand pushing towards these new innovative technologies.
And industries, even as old as the auto industry, are really getting
to harness that opportunity.

Ms. SCHOLTEN. Well, I thank you so much for your testimony
and for all the witnesses being here today.

I yield back the remainder of my time.

Chairman WILLIAMS. The lady yields back.

I now recognize Representative Ellzey from the great state of
Texas for 5 minutes.

Mr. ELLZEY. Thank you, sir. Thank you, Mr. Chairman.

On behalf of Mr. Meuser, I would like to ask unanimous consent
to enter a joint trade letter into the Record from National Mining
Association, American Exploration and Mining Association, the Es-
sential Minerals Association discussing the challenges small busi-
nesses face due to the U.S. Environmental Protection Agency’s bur-
densome regulations.

Chairman WILLIAMS. So moved.

Mr. ELLZEY. Costs have been going up in our country for a long,
long time. Under the Biden administration, the cost of living in the
United States is about 20 percent, has gone up about 20 percent.
Makes it very difficult for people to afford basic necessities.

The Environmental Protection Agency is a part of that problem.
They are one of the most oppressive rulemaking agencies, and they
are responsible for approximately $70.6 billion in new regulatory
costs in 2023. That is not borne by the companies. It is borne by
the consumers in passalongs. You can’t afford a truck, you can’t af-
ford your rent, you can’t afford to pay your taxes, you can’t afford
to go to the grocery store.

An additional 5.5 million paperwork hours for companies. These
regulations have increased the cost and regulatory burden for near-
ly every job creator in America. What the administration fails to
understand, these regulations have real world consequences for the
American public overall, and specifically small businesses.

We have the cleanest environment, water and air, of any indus-
trialized nation on the planet. And the only thing the EPA knows
to do is serve as a self-licking ice cream cone to provide for its own
existence and create new difficulties for American businesses to
succeed. And those businesses hire people who live in this country.

Now, in our appropriations bill in the Interior, we have cut back
on the EPA by 40 percent. Forty percent. And that is just a start.
But we have to get that appropriations bill through the Senate and
signed by the President so we can stop allowing the EPA to have
total control when they so choose over the business community in
the United States of America.

I have a lot of questions to ask three of you, and I wish I had
time to get to them. But I did some digging about our folks on the
end there. The American Sustainable Business Network is a merg-
er between 2021 American Sustainable Business Council and the
Social Venture Circle. And then I did some more digging on what
this group actually does. It is a member of the Declaration for
19

American Democracy Coalition, a left-leaning activist coalition that
advocates electoral administration policy changes.

And then I read a little bit further that they are a project of the
Public Citizen Foundation founded by Ralph Nader. And then I did
a little bit further digging. The foundation, located in Washington,
D.C., provides administrative and financial support to Public Cit-
izen, in addition to running its own research and media programs
with a focus on health, environmentalism, and limiting business
rights.

Make no mistake about what is going on with the EPA and
groups like our group on the end. This isn’t about American busi-
nesses and making them stronger. This is about shutting down
American businesses and outsourcing our guilt, like we have done
with the mining of our rare earth metals, which we need for our
national security and the very lives we lead every day for microchip
production, for energy independence. So we are going to limit LNG
production in the United States so that Germany is more depend-
ent on our enemy, Russia, for their natural gas.

This is harmful to national security. It is harmful for the security
of our families. It is making life more difficult for them.

Mr. Chairman, I appreciate what you have done in these hear-
ings on promoting American businesses, holding the Small Busi-
ness Administration accountable, trying to improve their ability to
help small businesses. But when somebody says they are trying to
help the 33 million small businesses in this country by making it
harder for them to do their jobs, and the restrictions on a five-bar-
rel-a-day production, well, limiting the ability for our medical com-
munity to clean the things that we use to take care of our Amer-
ican people, they are making it difficult to live in the United
States.

And I think it is about time to go back to the Administrative Pro-
cedures Act and do away with the EPA, because we already have
a redundancy in every state. Every state has their own EPA. In
Texas, it’s the TCEQ. And those TCEQ members do a very good job
of making sure that the air and the water in the state of Texas is
clean. We don’t need the EPA’s help.

I am about out of time. Sorry I didn’t get to ask any questions,
but it needs to be clear on what the agenda is of some folks in this
country when they claim it is about supporting American busi-
nesses.

With that, I yield back, Mr. Chairman.

Chairman WILLIAMS. The gentleman yields back.

I now recognize Ms. Maloy from the great state of Utah for her
5 minutes.

Ms. MALOY. Thank you, Mr. Chairman. I had a bunch of
thoughts I was prepared to share about federalism and how redun-
dant and unnecessary some of these EPA regulations are, but Mr.
Ellzey just did a fantastic job of that, so I am going to move on.
In fact, I wish I had said what he just said.

Ms. Wagner, first of all, thank you for your testimony. You are
a fantastic witness. And I have a high school graduating class of
32. I rarely meet people who can beat me on that, besides my sib-
lings, so great to hear about that.
20

And what you said really had a ring of truth to me. I grew up
in a small town in a rural area where people are dependent on re-
sources to make a living, and we have a built-n incentive. We learn
from the time we are tiny that we have a responsibility to take
care of the resources God gave us on this Earth. So thank you for
sharing that.

And to that point, reading through the materials for this hearing,
I am reading that small business optimism is very low. One reason
is the burdensome regulations that are coming from unaccountable
federal agencies that can’t be voted out of office, that don’t have to
go back and face the voters every 2 years like we do.

And the EPA isn’t just regulating pollution and protecting
human health anymore. They are trying to change the way we do
business in this country, which is outside of their scope. They are
part of the executive branch. We, as the legislative branch, have
the responsibility to act as a check on them. And that is why you
are here. That is what we are doing here today.

Overregulation kills main street under the weight of compliance
and also the cost of inadvertent noncompliance, when rules get so
burdensome that people don’t even know whether they are in com-
pliance or not. So I am getting to questions here.

Our friend Mr. Green on the end just said that he sees a 30-to-
1 return on regulation. For every dollar they spend, they get a $30
bump. And I want to go down the line with the other three of you
and ask you individually, Mr. Farris, you represent a lot of small
businesses. Do you find that to be accurate?

Mr. FARRIS. I would say that I would love to see those studies.
All of our studies do not show that.

Ms. MALOY. So your Members don’t feel like regulation from the
EPA helps their bottom line?

Mr. FARRIS. Not from what we are seeing right now. We can
work together on regulations. Regulations can be helpful, but what
we are seeing right now is they are not helpful, and they are all
set at zero to where, to your point, it is shutting down businesses.

Ms. MALOY. Thank you. Ms. Wagner?

Ms. WAGNER. I would say the inverse of the other witnesses,
duplicitous regulations cost money. They will never produce more
oil and gas or any cost savings for my business, which will hurt my
employees and the communities that we support.

Ms. MALOY. Thank you. That also has the ring of truth to me.
Mr. Aklog?

Dr. AKLOG. So, I work in an industry that is primarily regu-
lated by the FDA. And obviously, we all would accept that
healthcare technologies needs to be regulated. And so the issue is
really about smart regulations and coordination between the regu-
latory agencies to make sure that we don’t end up with adverse
consequences to patients. And that is what we are trying to accom-
modate here.

Ms. MALOY. And do you think that further regulations give you
a 30-to-1 increase in your profit margin?

Dr. AKLOG. I am not focused on our profit margin. I am focused
on patients and patient outcomes. And that, to me, is the over-
riding question here, is that we have to have regulations that pro-
21

tect patients, but don’t do the opposite, which is what we are facing
ere.

Ms. MALOY. Thank you. And during your testimony, it struck
me that, you know, the justification for these environmental regu-
lations is that we are trying to keep our air and water clean, pro-
tect human life. But in the case of removing something we need to
sterilize medical devices, it is having the opposite impact. We could
be taking human lives in the effort to protect human lives. You
don’t have to respond to that. Just an observation.

With that, Mr. Chairman, I yield back.

Chairman WILLIAMS. The gentlelady yields back.

I now recognize Representative Alford from the great state of
Missouri for 5 minutes.

Mr. ALFORD. Thank you, Chair. And I apologize for not being
here sooner. We have a lot of competition on the Hill today. Just
met King Abdullah from Jordan and Secretary Vilsack in another
hearing. But this is so important, and I wanted to be here for your
testimony.

I have read it. I appreciate you coming here on your own time
and your own dime, as I like to say, because I know that is part
of being American is coming before Committees like this. We are
concentrated on making America great again through making main
street great again. And I thank the Chairman and the Ranking
Member for holding this.

The EPA, of course, you know, was created by President Nixon
to monitor and enforce our national guidelines on the environment.
However, under President Biden the EPA has completely aban-
doned this mandate. Instead, taking their cues from radical envi-
ronmentalists, they are attempting to regulate entire industries out
of existence.

In 2023 alone, the EPA was responsible for approximately $70.6
billion in regulatory cost and an additional 5.5 million paperwork
hours for companies. The Biden EPA might be happy to learn that
America is actually reducing the amount of greenhouse gas emis-
sions and has been since 2007.

As the United States has drastically decreased our emissions,
communist China emissions have spiked. China’s emissions have
approximately doubled since ’06, when they became the world’s
largest emitter of greenhouse gases. While American emissions
have been constantly decreasing, the Chinese continue to increase
their pollution.

While the radical environmentalists would love to claim that
America’s progress is due to their activism, the data clearly shows
that this happened despite their best efforts. The reason American
emissions peaked in ’07 is because of hardworking independent en-
ergy producers, like Cooper Oil and Gas.

America reduced emissions and gained energy independence be-
cause of the shale revolution and the policies of the Trump admin-
istration. This has led to cheap and plentiful energy, including a
doubling of the natural gas produced since 2006. America reduced
emissions and gained energy independence because of our small en-
ergy producers, not because of the roadblocks thrown in their way
by radical environmentalists. As Ms. Cooper Wagner will surely at-
22

test, the shale revolution has been the greatest environmental boon
the world has ever seen.

Now to our questions. For Ms. Cooper Wagner, American carbon
emissions have declined year on year since ’07, as I mentioned.
Much of the progress has been due to increased usage of natural
gas from small-scale producers like your own. Why do you think
the Biden administration is proposing rules and regulations that
would crush small energy producers like yours if you are part of
the solution?

Ms. WAGNER. That is a fabulous question and I appreciate your
comments. And will even say something I don’t get to to most peo-
ple, you are welcome.

Our industry is fiercely private. We are a small mom-and-pop.
Again, I work with my dad and mom, with my husband and my
brother. We never knew that we needed to be so public and educate
regulators, legislators, and the general public about what we do
and the quality and quantity of life that we provide. I don’t know
if it is just a lack of education and how things work, why the lights
are on, why your cars are safe, why when there is disaster, you are
safe from it. And the majority of those reasons are because of fossil
fuels.

You know, I am not sure why there is a target on my back. And
as a mother of two young kids, I never try to be a doomsday sayer
and everything is bad and, you know, the big guys are after us. I
don’t like to live in that world. I believe there is good in all people
and good in this world. But it is a difficult line to walk as an E&P
producer and someone in the oil and gas industry, and I am not
quite sure they want to wipe us out, but it definitely feels that
way.

Those returns that you are talking about and leveling playing
fields between super majors and us don’t exist. I will never compete
with them. The economies of scale, we are in different markets, dif-
ferent everything. They can absorb erroneous regulations from the
EPA for no real environmental benefit and push that cost to the
end consumer. I can’t do that. I am the end. The buck stops with
me and my small company and my small business and our small
community.

Mr. ALFORD. Well, thank you so much. And, you know, they
like to say that ignorance is bliss. In this case, ignorance is dan-
gerous. It is dangerous to your company, your business, and to the
American people.

This administration has put the crosshairs on the backs of the
American people by demonizing fossil fuels with overregulation. We
have got to regain our territory. We must be energy independent
once again.

And with that, Mr. Chairman, I yield back.

Chairman WILLIAMS. The gentleman yields back.

I now recognize Representative Van Duyne from the great state
of Texas for 5 minutes.

Ms. VAN DUYNE. Thank you very much, Mr. Chairman.

The subject at today’s hearing is one of tremendous importance
and one we hear about again and again from small businesses. The
EPA is determined to overstep its authority and get in the way of
Americans and job creators. Small businesses are already having
23

to suffer 3 years of disastrous policies under the Biden administra-
tion that have driven up the cost of living, making food, electricity,
housing, and transportation nearly impossible to afford.

Last June, I, along with the Chairman and several other Mem-
bers of this Committee, sent a letter to the EPA Administrator on
their proposed rule to ban the use of PCE, which is used in dry
cleaners as a cleaning solvent, and, if banned, would force thou-
sands of small businesses to close their door. The EPA estimates
that their rule could cost businesses anywhere, and this is great,
this is just phenomenal work from the EPA, they are estimating
that it could cost businesses anywhere from $850 to $10.4 million.
That is a huge margin. And I want to know, I mean, how do you
plan as a small business for that type of a margin?

Last year, this Committee passed my bill, the Small Business
Regulatory Reduction Act, which requires the Small Business Ad-
ministration to ensure for each fiscal year that the cost to small
businesses of the administration’s rulemaking is not greater than
zero, while also requiring the SBA to issue a report on any regula-
tions issued by other federal agencies that impact small businesses.
And I am looking forward to expanding these provisions beyond
just the SBA and into EPA. And I think EPA is a perfect place to
start when you consider what is happening in our energy industry
and its huge impacts on our economy.

Ms. Wagner, thank you for being here today. I know it is a little
chillier here than at home in Fort Worth. I appreciate your testi-
mony. I appreciate your responses just now to Mark Alford’s ques-
tions. His questions were very similar to mine. This is what hap-
pens when you are one of the last speakers, right? All the questions
have already been asked. But I know that you have invested a lot
in what is going on in the environment. It is not in your best inter-
est, you know, for the environment to not be taken seriously and
to be unsafe.

Can you talk a little bit about those investments? And can you
talk about the overregulations, the regulatory burdens that your
small business, that Cooper Energy is having to face, and possible
solutions or what specifically you think could help get rid of some
of those regulations? If you have got any ideas, I would love to be
able to hear them.

Ms. WAGNER. Sure. Thank you. Thank you for the questions
and for the time. It is an honor to be here today.

The regulations that we have in place in our small company, we
employ a full-time person to just manage the regulations that we
have now. So just in our little company, it is a full-time job in the
office for staff, just on the paperwork side of things. For my guys
in the field, it is part of their job every day to make sure that these
regulations are followed.

More regulations for me are going to mean I am going to have
to hire more people with, again, no benefit from those regulations
to be able to pay those people, to be able to give them those good-
paying jobs in a rural area that are so hard to come by.

Again, regulations and being a part of a regulated industry, like
you have heard from the three of us, is important, and we are a
proud member of that. If EPA, if other regulatory agencies could
listen to some of the comments that we have submitted, the input
24

that we have tried to have, that seems to go—I echo your com-
ments on the difference between listening and hearing. We need to
be able to partner to be able to make good, responsible decisions
that aren’t going to wipe out small businesses.

We are a scrappy bunch. We make money on stuff that all the
majors have walked away from. We make money where you
shouldn’t be able to. But there is a whole economy of that that sup-
ports millions of vital rural economy Americans—American econo-
mies, rather, and these regulations will effectively wipe that out.
There are businesses that will not survive and jobs that will not
survive.

Ms. VAN DUYNE. I appreciate your testimony and your answer.

Dr. Aklog, I have heard from doctors in my district about the
concerns they have if the EPA moves forward with their proposed
rule banning ETO, which is used as a sterilization agent for med-
ical equipment. What type of alternatives exist if the rule is final-
ized? And how realistic are they for small businesses?

Dr. AKLOG. Thank you. There are a couple of other traditional
alternatives, such as steam heating and radiation that have been
used to sterilize medical devices, but they are just not appropriate
or they don’t work in the vast majority. So about 50 percent of
medical devices, the only currently available technology is ethylene
oxide. There is active R&D, and we are in the innovation business,
so we certainly welcome new types of sterilization. The problem is
that none of them are yet ready for prime time.

There is one example called vaporized hydrogen peroxide, which
is a gas like ethylene oxide, and in theory, could have some of the
benefits of being able to sort of work your way through the inner-
most parts of these complex devices. But it is really new, and we
don’t have the data. The processes of determining that they actu-
ally work is quite overburden.

Ms. VAN DUYNE. Thank you. My time has run out.

I yield back, but thank you for your answer.

Dr. AKLOG. Thank you.

Chairman WILLIAMS. The gentlelady yields back.

I now recognize Representative Hunt from the great state of
Texas for 5 minutes.

Mr. HUNT. Thank you, Chairman Williams, and thank you,
Ranking Member. I want to thank our witnesses for joining us here
today.

I want to look at some of the burdensome regulations that have
been implemented by the EPA and the Biden administration as
they continue to put more hurdles in front of businesses like yours,
ma’am, and our hardest working citizens in our country.

Ms. Wagner, I want to thank you so much, ma’am, for what you
have done. I want to thank you for your company. I want to thank
you for helping the smaller pieces of the oil and gas industry in a
rural part of our state where it is not the easiest to create and
thrive. Really appreciate you, ma’am.

And thank you for working to keep our houses cool in the sum-
mer and heated in the winter. Without you, your dedicated employ-
ees, and other companies like yours, our quality of life in this coun-
try would be way worse than it is right now, for the record.
25

President Biden has been actively calling for the end of oil, of the
oil and gas industry since the day and before the day he took office.
And he put the priorities of the radical left’s climate change agenda
over the needs of the American people and commonsense policies.

The administration is more than willing to use fossil fuels to
prop up their failing ESG initiatives, just as long as those fossil
fuels don’t come from America or American companies. We con-
tinue to see the Biden administration purchasing oil from Ven-
ezuela and critical minerals from child labor mines in Africa and
allowing China to continue to build their multiple coal-powered
plants each month while ignoring their climate footprint as they
continue to increase their climate footprint from time to time, from
generation to generation, although we continue to decrease our car-
bon footprint.

All foreign countries where they have less regulation, less over-
sight, and exponentially dirtier oil, we continue to see Joe Biden
and the climate cartel approving pipelines in Europe that allow
natural gas to flow freely into homes of European families while
killing the very same projects domestically.

Our American energy companies are world leaders in innovation,
productivity and accountability. I cannot think of a single energy
company that does not obsess over their compliance, field equip-
ment maintenance, and take general preventative measures on
their own outside of whatever regulations that are already in place
to ensure that we continue to operate at 100 percent capacity.

Ma’am, Ms. Wagner, this question is for you. What is your esti-
mated compliance cost over the next 5 years for the methane rule
and with other EPA regulations, and how does it impact your bot-
tom line?

Ms. WAGNER. Thank you. I appreciate your comments very
much.

Mr. HUNT. Appreciate you.

Ms. WAGNER. Thank you. The cost estimate currently, this is
also very ambiguous, and I hate to sit here and say I don’t know,
but it is not clear. So many things are not finalized. So many
things are being restructured. There is a tax that we are subject
to that goes into effect before the formulaic work and the empirical
evidence has been shown to know if I am subject to that tax.

I pay taxes. I don’t do tax law myself.

Mr. HUNT. I pay a lot of taxes.

Ms. WAGNER. Yeah. A whole bunch of taxes, yes, sir. I know
that there are companies that have already been so concerned and
so, quite honestly, scared so many small businesses that are living
in fear that they have hired some environmental companies to do
this just to find out if they might qualify. Because the environ-
mental companies can’t tell you for sure yes or no has cost small
operators like myself approximately $10,000. And the answer is,
thank you for the $10,000. Here is all the work we have done based
on what EPA has put out. I don’t know if you qualify or not. And
if so, if you do, it will be up to a range, like the Congresswoman
pointed out earlier, it could be hundreds of dollars if you don’t
qualify. It could be millions of dollars if you do.

The problem is, if you do or don’t qualify under these rules. what
I am concerned about as a small operator is maybe I am under a
26

threshold. Maybe I don’t emit, maybe I don’t fit the formulas. Prov-
ing the negative is going to be just as expensive as if I did. And
proving the negative means I am going to have to do all of the
same things that will not help my business. They will not make my
business more money to be paying those taxes, paying those royal-
ties, helping my communities. They are just going to be a net cost
that will wipe out businesses that are the size of mine and smaller.

Mr. HUNT. Would you consider it to be like a hidden tax.

Ms. WAGNER. I would consider it to be erroneous and over-
burdensome regulation.

Mr. HUNT. Understood. Quick, simple question for you as well.
Did you find it easier or more difficult to produce energy for the
American people today when Donald Trump was president or when
the current administration is now in office?

Ms. WAGNER. Our business practices basically sustain over 40
years, regardless of who is in office.

Mr. HUNT. Understood.

Ms. WAGNER. But I did not feel the target on my back that I
do since President Biden has taken office.

Mr. HUNT. Understood. I want to close with this, ladies and gen-
tlemen. As a candidate for President, Joe Biden again promised to
end the oil and gas industry. He said this with his own words, but
here is a dirty little secret. He only wants to end it in America.
Biden doesn’t have any problem buying dirty oil from Venezuela.
He doesn’t have any problem buying oil from our adversaries. And
Joe Biden and his colleagues want the oil. They just don’t want to
see how the sausage is made.

The Biden administration’s energy policy is out of sight, out of
mind. And as long as it is not being produced in America, the cli-
mate lobby won’t be upset. We have got to fix this.

And thank you so much. I yield back the rest of my time. Thank
you for being here, ma’am.

Ms. VAN DUYNE. [Presiding.] I now recognize Rep.
Gluesenkamp Perez from Washington for 5 minutes.

Ms. GLUESENKAMP PEREZ. Thank you, Chairwoman. And
thank you to the witnesses for being here today.

So before coming to Congress, I ran an auto repair in a machine
shop with my husband. We are an independent. Not especially lu-
crative, right? And I will never forget going into wrecking yards.
I remember I was picking up parts for, like, a 90s Toyota, and the
guy was like, the owner, a buddy was like, crying. He had an in-
spector there, so, right, wrecking yards, cheap land. It is not a
high-margin business. You are operating often in wetlands.

So the environmental impact, you know, and businesses like
mine, I mean, we didn’t cause the oil leak. We are fixing the oil
leak. We are stopping the oil from going into the river. And we are
the ones who are under scrutiny because we are the one fixing the
problem. And, you know, in these wrecking yards that we see get-
ting shut down all across the country, they are the independents,
usually, and they don’t have the money for the lawyers to navigate
the system.

And, you know, you think about what is the average consumer
going to do when they can’t get their Toyota Corolla fixed? Instead
of remanufacturing a part that is always been in America, they are
27

going to have to get some cheap thing from China that is going to
fail. And you think about the downstream effects on the economy
of shutting down these small repair shops and wrecking yards
when they are not compliant with EPA regulations. That hinders
a really important part of the supply chain.

And so, you know, I guess my question is how—this is the ten-
sion we see between the EPA’s mission, which I value. I like know-
ing my water is clean. I like knowing my air is clean. But I also
want equity and who is being held accountable and who has the
capacity to navigate these rules.

And, Mr. Green, in your opinion, how do you balance the needs
of the economy with that, like, lens of equity for the smaller compa-
nies that don’t have the infrastructure to navigate?

Mr. GREEN. I think the lens of equity should really be focused
on the communities that have been disproportionately impacted by
the negative health impacts and the environmental impacts, be-
cause their communities have often been overlooked, over-
shadowed, and underrepresented when they are making decisions
about where to put things that are going to create a lot of pollution
in their backyard.

Ms. GLUESENKAMP PEREZ. When you say “they are making
decisions,” like, who are you referring to about making the decision
to put their wrecking yard in the only place they can afford to put
it? Who is making that decision?

Mr. GREEN. The business.

Ms. GLUESENKAMP PEREZ. The small business.

Mr. GREEN. The business is making a decision.

Ms. GLUESENKAMP PEREZ. So then you want to hold the
small business accountable for not having the resources to go to a
wealthier neighborhood.

Mr. GREEN. I would want the small business to be accountable
for the footprint and their business decision and the impact that
their business is having on their local community.

Ms. GLUESENKAMP PEREZ. Mm-hmm. Yeah, I mean, I think
that, like, my experience is that the smaller guys are the ones who
are accountable. We are the ones who are sponsoring the Little
League team and donating to teachers. We are part of the commu-
nity. The small ones are the ones who are also the ones who can’t
navigate these rules.

When I bought my property, when I bought my auto shop, the
seller literally had a heart attack because that is his whole net
worth. And if there was an environmental finding there, like, he
is liable. He can’t afford to go to a nursing home after that, you
know. I mean, how do we balance? I don’t know if anybody here
has insight, like, how do we balance in creating a system that the
smaller guys can navigate, also?

Because I think a lot of this is just contributing to consolidation
is my concern. And then you really do have the big guys who don’t
go to the bake sale, you know, who aren’t selling Girl Scout cookies,
you know.

Mr. GREEN. Right. Can I take——

Ms. GLUESENKAMP PEREZ. Yeah, please.

Mr. GREEN. Yeah. And so I think part of it is that we are mov-
ing the American public away from the understanding of the true
28

intent of the EPA by using, you know, like kind of these tactics of
talking about how scary these regulations, how it is going to sup-
port, you know, countries over abroad that maybe, you know, it is
being placed in a way where people are anti-EPA rather than try-
ing to engage within the EPA process. So if we used a conversation
or had a conversation about these rules are something that we all
agree on and want to see happen rather than fear tactics when we
are talking about these things, rather than scaring those small
businesses away from the conversation, we could bring them into
the conversation.

Ms. GLUESENKAMP PEREZ. Yeah. How would you recommend
bringing those small businesses in? And how would you rec-
ommend—or can you point to things that you would

Mr. GREEN. Yeah. So at the clean power plan ruling, there were
in the Region 1 offices in Massachusetts, there was a overflow. And
we actually filled not only the hearing room, but also outside the
hearing room with small businesses that were around the Salem
Harbor Power Plant, around the Brayton Point Power Plant. So I
would actually say that small businesses, when there is the oppor-
tunity to engage, are engaging. Most of us here today are claiming
to or do support and represent the small business community. So
I think it is actually a words decision to bring those businesses in
and the mechanisms already exist to continue to have them.

Ms. GLUESENKAMP PEREZ. Thank you all for being here
today. Thank you, Mr. Green.

I yield back.

Ms. VAN DUYNE. Thank you. I now recognize Representative
Stauber from Minnesota for 5 minutes.

Mr. STAUBER. Thank you, Madam Chair.

To my colleague that just spoke, I couldn’t agree with you more.
I appreciate your comments about the small operators, the small
folks.

And Mr. Green, I couldn’t disagree with you more about the
EPA. Let me tell you something. The EPA has shut down mining,
manufacturing, logging, and timber producing in our great state, so
I disagree with you fundamentally on the EPA trying to work with
them. Okay. I have seen the devastation. I have seen our farmers
and ranchers. The WOTUS rule was devastating, devastating to
small businesses. And so I think—I read your comments. I appre-
ciate where you come from. But sir, I adamantly disagree with you.

The Biden administration is run by extreme radical environ-
mentalists who abuse the law and bend it to their will. The
unelected bureaucrats at the EPA are by far the worst offenders.
EPA regulations constantly attack my constituents and our way of
life. They restrict our mining operations, our logging operations,
and wildlife management. They force extreme Green New Deal
policies on our businesses without care for the overwhelming costs.
And now they are going after our healthcare.

The proposed rule on ETO sterilization, ethylene oxide steriliza-
tion, that technology will eliminate a chemical used to sterilize
medical equipment. Eliminating ETO would require manufacturers
to change how they sterilize medical equipment, either adopting
more costly or less effective solutions.
29

Additionally, there are many instances where ETO simply cannot
be replaced by other sterilization methods. Tools such as res-
pirators, heart valves, pacemakers, and catheters can only be prop-
erly sterilized by ETO as other methods are ineffective or even
harmful.

Make no mistake, this rule will increase costs, reduce access, and
eliminate services in our healthcare industry. And rural America is
always the first one negatively impacted. Rural America, rural
healthcare, rural hospitals matter.

Dr. Aklog, each year millions of separate medical instruments
are needed for nearly 1 million breast biopsies, 300,000
hysterectomies, 500,000 open heart surgeries, and the 1.1 million
C sections that are performed each year. Are the instruments for
all these procedures just mentioned sterilized by ETO? And what
would be the impact if they were not available due to the lack of
sterilization?

Dr. AKLOG. They are. The answer is—the simple answer is yes.

Mr. STAUBER. Microphone. Thank you.

Dr. AKLOG. Apologize.

Mr. STAUBER. I am hard of hearing. I am an ’80s metalhead.
Go ahead.

Dr. AKLOG. The answer is yes. So all of the examples that you
gave, and I could list numerous more, those are kits, surgical kits
that are packaged for use in surgery, and they require a gas to
penetrate the packaging in order to be able to offer a sterile device.
And so the answer is, they are—that is the only option for those.
And not having that would have, again, a devastating impact on
delays for surgery and potentially death and harm.

Mr. STAUBER. And, you know, you added “potentially death and
harm.” Here is the EPA making these decisions.

Under EPA’s proposal, millions of products would require re-
validation. What would this mean for capacity and supplies of the
critical medical technology needed for patient care?

Dr. AKLOG. In its current form, it would have a significant im-
pact. So to revalidate, even if there was an alternative for those,
to revalidate that technology, you have to go through a very rig-
orous FDA process, which we all understand it is part of what we
do every day. And that to revalidate a complex technology can take
many, many years. So the idea that you can channel into an alter-
native quickly without having an impact on patient care, it is just
not true.

Mr. STAUBER. Do you think small businesses like yours feel
heard in the federal rulemaking process?

Dr. AKLOG. I think, thanks to organizations like AdvaMed,
small businesses like myself do actually have a say. And I would
say there is engagement, and that is why we are here. I am here
to hopefully continue that and send the message that there are al-
ternatives that are less onerous, that, you know, where the time to
implementation and flexibility on standards can mitigate the risks
that we see with the rule as it is currently proposed.

Mr. STAUBER. We must do more to increase the affordability
and accessibility of healthcare. And the EPA regulations just put
more people in harm’s way.
30

As a reminder for this panel, $360 billion of additional regula-
tions put on our small businesses and farmers by this administra-
tion. And I will repeat that, 360 billion. That is with a B.

Madam Chair, I yield back.

Ms. VAN DUYNE. I now recognize Rep. Bean from Florida for
5 minutes.

Mr. BEAN. Thank you very much, Madam Chair. Good morning
to you and good morning, Small Business Committee. Lady and
gentlemen of the witness panel, good morning. We are glad to have
you here.

Hats off to all small business owners. I have been a small busi-
ness owner. You are often the first to show up for work, the last
to leave. You are the last to get paid. And in a perfect world, it
is just hard to run a business. It is just hard, let alone when the
invisible hand of government comes and tries to push you down
and stifle you. That invisible hand is not invisible anymore. We see
it, we feel it. And hats off to you.

Has it ever been this bad? Anybody want to jump in? Has it ever
been this bad? Ms. Wagner, you want to jump in? What say you,
has it been this bad before?

Ms. WAGNER. I have the history. I am not quite 40 years old,
and I keep saying my company is 40 years old. Well, that is be-
cause it is the second generation, and my parents started it from
nothing themselves. The same with farming and ranching. It is five
generations.

So while I don’t have the experience of myself, I have learned
from the experience of generations of my family, and in telling sto-
ries of this is what I am facing. This is what it is like now. The
generations past, my parents, my grandparents say to me, I can’t
believe that this has happened in our great country. I can’t believe
that they are making it so hard for us to feed the world and fuel
the world and do it cleaner and better than anywhere else in the
world.

Mr. BEAN. Amen.

Ms. WAGNER. It is shocking. It is disheartening.

Mr. BEAN. You would testify today it has never been this bad
or even your folks, when you have lunch with them, they say, it
has never been this bad.

Ms. WAGNER. I have their history to go off of.

Mr. BEAN. Very good. Well done.

Mr. Farris, you have testified and given us that information. We
are now over $8 trillion in just crazy rules and regulations that
have come down. That is an all-time high. That is 12 percent of our
GDP. How about that? Often duplicative or just wacky rules.

We all want to live in a safe, clean environment. But you say we
have gone too far. Is that correct?

Mr. FARRIS. Absolutely. I have only been around for a couple of
decades working on this. I haven’t seen anything like this on-
slaught. Every regulation coming out near zero, every regulation
targeting consumer choice, doing away with consumer choice and
doing away with entire industries. So, no, sir, I haven’t seen it as
bad as this.

Mr. BEAN. Ten four. Okay. So they are making rules. They
make rules. Do they, A, give you all a chance to have input? Don’t
31

they come have public hearings and say, Ms. Wagner, how would
this affect your business? Do they say to your team members and
members of the Manufacturers Association, do they say, will this
adversely affect, are we going too far? Do they give you that oppor-
tunity? Does anybody get a chance to speak at these rule hearings?
Do they even have rule hearings?

Mr. FARRIS. I will say that we have been asked. I don’t believe
that we have been listened to, but we have been asked.

Mr. BEAN. Okay. That is my next question. Do you feel listened
to or do you feel like you are just talking to a brick wall? What
do you think, Ms. Wagner? Is it a brick wall or do you feel like they
are listening to you?

Ms. WAGNER. It is a brick wall.

Mr. BEAN. Brick wall.

Ms. WAGNER. We have submitted through the Texas Alliance of
Energy Producers, which represents 3,000 members in the state of
Texas of small to midsized independent operators. we have sub-
mitted multiple comments with very specific here are the problems,
here are the issues, and nothing changes. It is falling on deaf ears.

Mr. BEAN. Would you say they have a narrative going in and
that is what we are going to end and it doesn’t matter what you
say? I don’t even want to hear what you say. We already know
what we are going to do.

Ms. WAGNER. Unfortunately, I think you are correct.

Mr. BEAN. Do you think they know that? In fact, this is some-
thing I learned on the Steve Scalise energy tour last year, going to
spend a couple of days in the Gulf on a platform to look at how
we produce energy in America, learning that no one does it cleaner
than America, no one does it safer than America. Do you think peo-
ple that are making these rules understand that? Anybody want to
jump in?

Ms. WAGNER. They don’t.

Mr. BEAN. They don’t. So what happens when we—what I have
learned, would you agree with this statement, that when we, in
fact, we learn it is not a battle that the Biden administration has
on oil and gas, it is just American oil and gas? Because when we
don’t allow it to be made here or produced here, we are going to
go somewhere else where they don’t make it as clean or as safe as
others. True statement?

Ms. WAGNER. Very true.

Mr. BEAN. Very true. All right. Let’s talk about what happens
if the unthinkable happens and Cooper Oil and Gas goes away or
just succumbs to the pressure. What happens to your wells? What
would happen?

Ms. WAGNER. Depending on how we go away, a lot of the issue
that we have in this country is not with responsible operators. It
is with things from the past or things that have been forced upon
them. If regulations are forced upon small operators, there will be
no resources for them. You will have more abandoned wells, not
more production, you will have less production in the United
States.

The fallacy and all of that issue, which is its own environmental
hazard, is that the demand for our product goes nowhere. We must
have fossil fuels to power our lives as they exist today and for the
32

foreseeable future. And if you don’t get it here, you are getting it
from overseas. There is no Texas Railroad Commission, API, EPA.

Mr. BEAN. Let me just say, amen. Thank you.

And I yield back, Madam Chair.

Ms. VAN DUYNE. Thank you very much. I would like to thank
our witnesses for your testimony and for appearing before us today.

Without objection, Members have 5 legislative days to submit ad-
ditional materials or written questions for the witnesses to the
Chair, which will be forwarded to the witnesses. I ask the wit-
nesses to please respond promptly.

If there is no further business, without objection, the Committee
is adjourned.

[Whereupon, at 11:34 a.m., the committee was adjourned. ]
33
APPENDIX

TESTIMONY OF BRANDON FARRIS, VICE PRESIDENT OF DOMESTIC POLicy,

NATIONAL ASSOCIATION OF MANUFACTURERS

BEFORE THE U.S. HOUSE COMMITTEE ON SMALL BUSINESS

Hearing on
“Burdensome Regulations: Examining the Impact of EPA Regulations on Main Street.”

Fes. 14, 2024

Good morning, Chairman Williams, Ranking Member Velazquez and distinguished
members of the committee. Thank you for the opportunity to appear before you and for holding

this important hearing today on how the regulatory onslaught is hurting small businesses.

Introduction
My name is Brandon Farris. | sérve as the vice president of domestic policy at the

National Association of Manufacturers. The NAM is the largest manufacturing association in the
United States, representing small and large manufacturers in every industrial sector. At the
NAM, we advocate policies that grow manufacturing in the United States and improve the lives
of everyone, including the families of the nearly 13 million people who make things in America.
The vast majority of the NAM’s members are smail and medium-sized businesses, giving us key
insight into the issues they face every day.

| come from a small business family. My parents ran a driving school. My father,
brother and | laid tile. My brother has a woodworking shop. | have seen firsthand how
small businesses and entrepreneurship can raise the quality of life for families and

communities. | have also seen the burdens that can accumulate quickly as family-led
34

businesses attempted to meet their customers’ demands while struggling to comply with
complex and costly, narrowly-tailored government mandates.

Small businesses are essential for our economy. A recent Small Business Administration
study shows that small businesses account for 44% of all U.S. economic activity.’ In the
manufacturing sector, the majority of firms are small. According to the U.S. Census Bureau, in
2021, there were 238,851 firms in the manufacturing sector, with all but 3,920 firms considered
to be small (i.e., having fewer than 500 employees). In fact, three-quarters of these firms have
fewer than 20 employees, and 93.4% have fewer than 100 employees. These firms are the
backbone of the manufacturing supply chain, often producing key components for larger firms
making complex finished goods for consumers, the military or industrial uses. Manufacturing in

America could not survive without a thriving small business sector.

Small businesses pay severe costs to comply with regulations

Manufacturing faces significant headwinds in the form of the cost, complexity and
uncertainty associated with overreaching and burdensome federal regulations. To put it bluntly,
.manufacturers are facing a regulatory onslaught. This onslaught has a direct impact on
manufacturers’ ability to invest, hire and grow in the United States—threatening America’s
leadership. .
The NAM recently released a landmark study analyzing the cost of unbalanced regulations
through 2022,? and the results are shocking:
« The total cost of federal regulations is an estimated $3.079 trillion, an amount equal to
12% of U.S. GDP. The average U.S. company pays $13,000 per employee per year to

comply with federal regulations.

3 https://nam.org/competing-to-win/cost-of-regulations/
35

e For manufacturers, the cost of federal regulations is roughly $350 billion, a 26% increase
from 2012. The regulatory burden on manufacturers is larger than the economies of 29
U.S. states.

e The average manufacturer in the United States pays $29,100 per employee per year to
comply with federal regulations—more than double the regulatory burden faced by other
industries.

« The burden on small manufacturers is even more severe, as they incur regulatory costs
of $50,100 per employee per year. A small manufacturing firm with 20 employees bears
more than $1 million in compliance costs per year.

The regulatory compliance burden for small businesses is more than three times the cost borne
by the average US. company. Small businesses are exhausting time and resources to comply
with inefficient, duplicative and unnecessarily burdensome regulations, instead of investing in
new machinery, hiring. more workers or developing new and innovative products. Surveyed
manufacturers indicate that they could enhance their competitiveness if the cost of federal
regulations were reduced, reallocating compliance funds toward compensation and hiring,
research and development, sales and marketing, enhancing price competitiveness and

improving return on investment.

Revised particulate matter standard can freeze economic growth

The NAM analysis only reflects regulations in place as of 2022, but new regulations or
expansive revisions of existing ones have been especially disruptive and will surely chill
manufacturing growth. For example, the Environmental Protection Agency recently finalized an
early reconsideration of the National Ambient Air Quality Standards for fine particulate matter.

The revision moved the current standard of 12 ug/m3 down to 9 yg/m3—which is approaching
36

or lower than natural background levels for many parts of the country.® The revised standard will
make manufacturing in the U.S. less competitive globally and will create permitting gridlock
throughout the country, as permit applicants will have to model to the new standard within 60
days. Ultimately, states will have to choose which new investments should be allowed to break
ground. This revision was made despite the EPA itself saying that some 70% of particulate
matter comes from nonmanufacturing sources, such as wildfires (29%), agriculture and
prescribed fires (15%), crop and livestock dust (12%), unpaved road dust (10%), paved road
dust (3%) and “dust” (2%).‘ As we saw last year, wildfires have had a demonstrable effect on air
quality in the U.S.

This new regulatory burden will affect manufacturing investment directly, potentially

diverting cutting-edge factories to other nations. The EPA's revision is far more stringent than
‘the guidelines in place in Europe, where the current EU standard is 25 g/m3 with a proposed
reduction to 10 ug/m3 by 2030. And this revision seems to ignore the fact that the U.S. has
improved its air quality dramatically. The EPA’s 2022 Air Trends and National Emissions
Inventory reports show that PM2.5 concentrations have declined by 42% since 2000,° driven by
major emissions reductions from both mobile sources and the power sector. As a result, our air
is cleaner than ever.

When a standard is set at naturally occurring levels, there are fewer tools available for
compliance. The vast majority of PM2.5 emissions come from natural sources, yet the
manufacturing industry will shoulder the greatest burden to comply with a standard that in many
areas of the country is unachievable. If the air quality in an area reaches the level proscribed
under the new standard, then no economic growth can happen and no new factories or

infrastructure can be built without placing the area into nonattainment. Furthermore, even an

3 https://www.epa.gov/air-trends/particulate-matter-pm25-trends
4 httos://www.epa.gov/system/files/documents/2023-06/PM_2022.pdf
5 httos://gispub.epa.gov/air/trendsreport/2023/#air_ trends
37

area where air quality currently complies with the new standard may not be able to build new
projects unless sufficient headroom exists to allow projects without placing the area into
nonattainment. This will hit small businesses particularly hard because of the time, cost and
expertise necessary to model their operations to the new standard quickly. Furthermore, many
state permitting systems work on a first-in/first-out system, meaning that expansions or new

factories for small businesses may not be able to be permitted for years to come.

Requlatory Onslaught

_ This is just one example of an agency action that will have far-reaching effects. across
the manufacturing economy. Many other proposals are moving toward finalization. -

« The EPA has proposed numerous regulations that include burdensome reporting
requirements and would restrict or create a de-facto ban on PFAS production or
use. The carbon-fluorine bond that is the hallmark of PFAS is unmatched in
chemistry, meaning that for many of its current uses, such as semiconductors,

EV batteries, medical devices and items necessary for national defense, there
are no existing replacements. These proposed restrictions would force
manufacturers to abandon domestic production of critical items and instead rely
on foreign production.

e Another proposed EPA regulation would impose new requirements on natural
gas and coal power plants, which account for more than 60% of our nation’s total
power generation, requiring widescale deployment of carbon capture and
sequestration/storage or co-firing with hydrogen. Noncompliant facilities would be
shut down. Because the technologies required to meet the rule are unlikely to be
available at scale in the timeframe required by the EPA, a large portion of our
nation’s power supply runs the risk of being taken offline if the rule is finalized as

proposed.
38

The EPA has proposed a regulation at levels so low it would create a de facto

ban on the production and use of ethylene oxide, which is used to sterilize

medical devices, including personal protective equipment used by doctors and

hospitals, as well as other equipment that cannot be sterilized by steam.

There are multiple conflicting vehicle emissions standards, including the EPA’s
proposed greenhouse gas and tailpipe emissions standards that would increase
the cost of both manufacturing and purchasing vehicles. The EPA proposal
would reduce consumer choice, as it requires two-thirds of vehicles produced to
be battery-electric by 2032, notwithstanding the current limits on charging
infrastructure, critical minerals and grid capacity that would be nearly impossible
to address at this scale in this timeframe.

The Toxic Substances Control Act program is vital to the innovation that drives
our country. To ensure continued access to the newest chemicals that can make
essential technologies even more effective and efficient, the TSCA needs to be
administered in a manner that provides timely decisions on which manufacturers
can rely. However, the EPA has proposed additional barriers and requirements
that could stunt manufacturing innovation, such as potentially lowering the
scientific rigor of risk evaluations by eliminating the definition of “best available
science”. The EPA's proposal also now essentially ignores the existence of

Occupational Safety and Health Administration standards requiring

- manufacturers to use personal protective equipment, creating a duplicative need

for manufacturers to prove they follow rules that have been in place for
decades—rules governed by another agency that is better positioned to
determine whether industry is following guidance. The EPA is mandated to

review new chemical applications within 90 days; however, the vast majority of
39

approvals take much longer, and these new requirements may further extend
that approval period, delaying deployment of new, efficient products.®

e The Securities and Exchange Commission’s proposed climate disclosure rule
would increase manufacturers’ compliance costs dramatically, divert resources
from job creation and growth, expose companies to increased liability, reveal
proprietary and confidential information and ensnare wide swaths of the
manufacturing supply chain. These effects would be felt throughout the industry,
including by small and privately held businesses.

e The Department of Energy recently announced a freeze on pending decisions to
export liquefied natural gas. Since the U.S. shale revolution, manufacturers in the
U.S. have depended on access to clean, affordable, reliable American natural
gas—and our abundance has allowed the U.S. to bolster our allies’ energy
security. For instance, after the invasion of Ukraine, the EU was able to slash
Russian gas imports to one-third of 2021 levels mainly by tripling U.S. imports.”
At a time when energy security is paramount, we cannot leave our allies or our

manufacturers in the cold.

Small businesses are vital to our economy and our lives. If we fail to reduce the
regulatory burden on them, the U.S. is at risk of threatening the entrepreneurial spirit that has
allowed small businesses to thrive. On the other hand, if we reduce their burden and costs,
there is no limit to what small businesses in the United States can accomplish—for the good of

our people and the good of the world.

7 https://www.politico.com/news/2024/01/19/biden-europe-gas-exports-00136671
40

As the NAM has emphasized consistently, regulatory reform is not about cutting corners.
It is about keeping up with the world around us. It is about ensuring regulatory certainty that can
guide investment decisions and ensure that this country’s economic competitiveness is not
outpaced or outflanked or overtaken by nations that do not share our values.

Thank you for inviting me to testify today. | look forward to continued engagement with

members of this committee.
Al

Testimony
of
Mrs. Cye Cooper Wagner
Executive Vice President, Exploration

Cooper Oil and Gas, Inc.
Before

House Small Business Committee

“Burdensome Regulations: Examining the Impact of EPA Regulations on Main Street
2360 Rayburn House Office Building

February 14, 2024

Chairman Willams, Ranking Member Velaquez, and Members of the Committee,

Thank you for the opportunity to submit testimony in today's hearing. The expected adverse
impact of EPA’s regulations, particularly those related to methane, on small businesses like mine
and others across Texas and the nation is of great concern and an important topic to discuss. I
thank you for your careful consideration and the opportunity to share my perspective and
experience, which is unique. My background is multifaceted in professional disciplines and
steeped in real world everyday experience of challenges — and reward — that comes from running
a successful small business. I am a past Chairman of the Board — and active current member — of
the Texas Alliance of Energy Producers, the 3,000-member strong association of independent oil
and gas operators in the state. My experience and role in the Alliance helped to provide me with
a deep understanding of how common my experiences are, and the extent to which small
business ethos are reflected and shared by other small operators in our industry — not just in
Texas, but across the nation. ,
42

My Small Business — An Introduction

I grew up in rural North Central Texas and went to school, played sports, and worked in the
small communities surrounding us — towns the size of 200 to 3,000 people — total. I graduated
from Texas A&M University with a degree in petroleum engineering and a minor in business. In
my collegiate and post-collegiate career — I have been fortunate to work with the smallest of the
small (my family company), large independents (Burlington Resources, EOG Resources) and up
to a super major (Chevron). After graduation and working for a few years for EOG Resources, I
decided to ask my father if ] could join the family business. It has now been 15 years since I have
been running our family business — and in the last 10 years — my husband and brother have
joined me in that endeavor as well. We are a true mom and pop — my parents started the business
themselves over 40 years ago. We have about two hundred wells across Texas and produce about
450 barrels of oil and a million cubic feet of gas (1,000 mcf) a day. A majority of our wells are in
the rural areas where I grew up. Our wells are not ones that make headlines for thousands of
barrels a day or millions of mcf of natural gas — they very much marginal producers with only
five-barrels of equivalent production per day, and usually less.

I am genetically predisposed to have responsible stewardship in my veins, and for the almost 40
years I have been alive it has been a passion that I will pass on to the next generations in my
family. Outside of my role as a second-generation mom and pop oil and gas producer, I am a
fifth-generation wheat farmer and cattle rancher. These commodities are the only way of life I
have known, and I have chosen to make them not only my career, but my passion to steward
these natural resources surrounding us. ;

Across our business, we employ eleven full-time people including myself and have about twenty
monthly contract positions. We also employ even more service contractors across Texas in our
operations monthly for whom, it is important to note, the entire company payroll is one or two
persons. Our small company is one of the large employers in a multi-county area in Texas that
offers 401K retirement, health insurance and paid leave and is a vital piece of the survival of this
rural area. We have been in business for 40 years and in that time, we have never taken
bankruptcy, nor had massive layoffs or nor taken (or been provided) government assistance ~
outside of the PPP program during COVID.

Our impact on the communities we proudly serve is significant. The foods we produce help feed
people across the state and the country. The ad valorem taxes that we pay from our wells
contribute directly to the rural hospitals, school districts, and local municipalities in our
operating regions, and the community support that we provide is the lifeblood of the area. The
royalties we pay are typically to retirees or elderly whose entire income is that of their social
security and royalty checks.

In everything I do in both those vital economic and societal endeavors, Iam a staunch supporter
of clean air, clean water, and doing what is right for our Earth — something I try to teach my two
young children daily.

Discussion topics heard in our family are often:
43

e “This is how we farm this wheat crop responsibly,”

e “This is how we care for these thousands of cattle — all natural, with no steroids or
antibiotics — their health, the land they need to graze, and the water they drink,”

¢ “This is how we hunt, fish, and manage this wild game and their natural habitats,” and

e “These are the oil wells that mommy and daddy drilled and produce here in the middle of
all of it.” :

Values of hard work, dedication to community, and good stewardship of our lands and waters
have been followed in our industry and businesses for many, many years; we’ve just never felt
the need to advertise it.

We fight against a cyclical market, rising supply and service costs, labor shortages, and more so
that our fellow citizens can have the fuels, technologies, schools, and communities that we create
and support.

Unfortunately, we did not understand that, as a private industry, we needed to provide greater
public information about what we do. We did not realize the massive lack of education about .
how things are made, touched, and used daily (that are direct and indirect products of our daily
toils) and the repercussions of that shortfall to our industry. However, in recent years, we have
come to realize that we cannot just sit back and hope the legislators and regulators do what our
industry needs to survive and continue to allow us to support our families and communities.

And that is why I am here before you today. To tell my story and hopefully shed some light on
the important reality that frequently well-meaning and well-intentioned laws, rules, and
regulations, often miss the mark in development and application. But equally important, as you:
will see from my testimony, much of the regulatory framework at the federal and state level are
in place and working.

Are things perfect? Of course not, not in my industries nor any others. However, I am also here
to support those in Congress who feel the need to do more for small businesses. We should focus
on implementing regulations and policy that will help us do our jobs better and encourage
partnership with small operators for the betterment of our nation. That would be a productive and
mutually beneficial working relationship between the current administration over what seems to
be happening — a never ending effort to pursue an assault of regulations and taxation that are
duplicitous and punitive for our small business will do more harm to our company, our
employees, and the communities we support with no clearly defined benefit to the environment.

We are a voice that is not heard very often, if at all. And yet we are the leading stewards of our
great country’s natural resources.

Our Operations — Oversight and Regulation are a Part of Daily Life

Many of the super majors and large independents that are typically heard from in the public
forum function on entirely different economic scales than our little mom and pop. The marginal
wells we operate cannot support implementation of commercially marketed automated
monitoring equipment. However, necessity is the mother of invention they say, and we have
44

proactively taken steps — with no requirement from any legislation nor regulation — to monitor
and maintain the responsible management of our production. My husband created a production
monitoring app on his own that our employees and contractors use to allow daily monitoring of
all of our operations across Texas. Again, this wasn’t required — this was the right thing to do.
Our mom and pop is not alone in that thinking — we bootstrap and scrap in economically efficient
ways to protect our producing natural resources — it is a point of pride to do it better and cleaner
than anywhere else does in the world.

I also want to give you a sense of what regulated life is like in Texas. We are regulated by the
popularly elected Texas Railroad Commission, and we have a robust set of regulations that we
must abide by to be viable operators — in my company, in “oil and gas friendly Texas”, we were
inspected 297 times in the calendar year of 2023. Since August 1, 2015, my company has been
inspected 1,832 times. I am proud to say that we have remained in good standing with the Texas
RRC for the 40 years of our existence. Our record of success speaks for itself, and my company
is not alone in that record in a lengthy tenure of business — there are other small operator mom
and pops just like mine across the country.

Those initial inspections are conducted without notice or warning — we must be always
compliant to protect our products as well as the air and land on which we operate — or face fines,
penalties or losing our permitted approval to sell our products or license operate at all in the state
of Texas. These records of inspection are public — there is nowhere to hide when it comes to our
business operations. Again, we (as other small businesses in our industry) pride ourselves on
doing it better and cleaner than anywhere else in the world and support fact-based, cost-benefit
proven legislation and regulation for our industry. These regulatory inspections from our state
officials maintain not only state-mandated rules and regulations, but federal-delegated standards -
that have been placed in state agencies, and also equipment-design standards set by API
standards ~ we are required to follow all rules and regulations for clean, safe and responsible
production standards across every aspect of our operations, and do so better than anywhere else
in the world to deliver a vitally demanded product to market.

Oil and Gas Operators in Texas and the Nation - A Success Story by Any Measure

I and my fellow Alliance members are immensely proud members of a highly technical, ever-
advancing, rigorously regulated oil and gas industry.

We produce oil and gas for the world cleaner than any other country in the world. In Texas alone
we have sextupled our production outputs and /owered our emissions — without the federal
government intervention. We did this because we are stewards of our resources, not wasters.

It was in Texas that the highly successful combination of horizontal drilling and hydraulic
fracturing was perfected and deployed to scale in the Barnett Shale in the 2000s. (The Barnett
Shale is a natural gas production region in north Texas). This is where I began my career after
college. Those technologies were then put to work in other producing regions around the country,
bringing forth significant volumes of crude oil and natural gas production in the Bakken in North
Dakota, the Marcellus in Pennsylvania and others.
45

That also includes the Eagle Ford Shale in South Texas, from which scarcely a barrel of oil was
produced until 2008, but by 2015 was adding over 1.7 million barrels per day to U.S. output.

The most impressive producing region in the country, however, is the mighty Permian Basin,
contained primarily within Texas. In 2010, the Permian Basin was producing under 1 million
barrels per day and is now producing nearly 6 million barrels per day, generating the same or less
greenhouse gas volumes now as in 2010.

That said, crude oil and natural gas production take place in every corner of the state. Of the 254
counties in Texas, some measurable, reportable volume of crude oil and/or natural gas is
produced in about 85% of them. Though the Eagle Ford was the shiny new rose in 2008 and
after, and the Permian Basin is the behemoth, production elsewhere in Texas comes from a
number of legacy fields including the East Texas Field, the Panhandle, North Texas, West Central
Texas, the Gulf Coast, and others.

The life cycles of these fields and their producing wells look very similar and are characterized
by declining production over a long period of time. That is why the majority of wells in Texas
are “marginal”, or low volume wells, and a sizable chunk of those are “stripper” wells, producing
15 barrels per day or less, and/or 90 mef per day of natural gas or less.

The only way to grow production, then, is to drill new wells to replace the declining production
from existing wells, and, importantly, to increase productivity and efficiency — more crude oil

and natural gas with fewer resources deployed to produce them - and that is what has happened
in the Permian Basin. ‘

Even though most of the life of crude oil and natural gas wells is spent with production in
decline, the useful economic life of those wells is typically decades long, and the majority of a
well’s productive life may be spent as a low volume well.

The most recent well count data from the Railroad Commission of Texas is from November
2023, and indicates 240,025 active producing wells, of which 162,789 are producing crude oil
and 77,236 are producing natural gas.

Of the 162,789 crude oil producing wells, less than 10% (9.5%) are producing more than 100
barrels per day, which means that over 90% of all crude oil producing wells in Texas are
producing less than 100 barrels per day.

Just over 25% of all crude oil producing wells are producing between 10.and 100 barrels per day,
and over 65% of all crude oil producing wells are pumping out less than 10 barrels per day At
some point, the wells producing over 100 barrels per day will fall into the 10-100 bpd range, and
many of those will, in turn, ultimately fall into the less than 10 bpd range.

Of the 77,236 gas producing wells, less than 5% (4.6%) of those are producing more than 1,000
mcf/day, only 488 of which are producing more than 5,000 mef/day. That means that over 95% -
over 73,200 wells - of all producing natural gas wells in Texas are producing less than 1,000
mef/day.
46

And most of those are producing less than 250 mef/day. As of November 2023, 66,381 natural
gas wells, or 86% of all natural gas wells, are producing less than 250/mcef per day. And a great
many of those are producing substantially less than that.

The national production picture looks very similar.

This data makes it clear that the oil and gas industry in Texas (and the U.S.) is an industry
characterized by a high number of low-volume wells — and by a high number of smaller to mid-
size companies that are operating those wells.

This is an effective and thriving business model under market conditions that are not altered by
damaging federal government policies that put these wells and companies at risk.

On every single one of these wells:

e Employees and contractors are paid to service and manage their operation and production
on a daily basis.

¢ Payments are made monthly to working interest and royalty interest owners, and for
many, this may be an important addition to monthly household income; further, the
spending of these dollars represents an important infusion of activity as it ripples through
the local and state economies.

e Ad valorem taxes are paid to municipalities, local school districts, and hospital districts in
their areas of operation based on the reserves these wells are producing.

e The state budget is supported by severance tax payments, the sales tax, and other direct
tax payments by oil and gas operators in Texas.

The loss of one third to one half of these wells as a result of the EPA’s vast regulatory overreach
represents an unimaginable negative impact to these regions of the state and the communities
within them.

It is true that, while these wells comprise the vast majority of wells in Texas and across the U.S.,
the volume of production from those wells does not. However, the volumes are not statistically
insignificant, and the lost production from one third to one half of those wells would represent a
shortage in production that would either raise prices to consumers, have to be replaced with
imports, or both.

Virtually irreplaceable, however, are the jobs, direct payments on production, local taxes, and
local economic support provided by the ongoing existence and operation of these wells.

Shutting in a massive number of wells in Texas and the U.S. and imperiling a great many of the
companies that operate them represents a set of nasty trade-offs for the policies now being put in
place by the EPA, and we should not pretend they do not exist.
47

Conclusion

The regulations being discussed in this hearing would not only be of high cost to my small
generational family business and no benefit to the environment, but also detrimental to so many
that we uplift with our jobs, contract work, tax dollars, royalties, donations and more in our
important, vital, rural but often unheard from and underrepresented communities. Further, it has
been touted elsewhere by supports of the IRA tax and the related regulations have industry
supported, and that is not quite correct. That support comes from very large super majors that
employ thousands and thousands of employees, with vast operations and resources to pass those
costs on to consumers.

I can assure you that methane regulations that provide no credible environmental gain and
provide certainty of increased operational costs for companies like mine and will hurt all I have
discussed today ~- my small family business, the local rural economy, schools, hospitals and
community members. Those regulations will not hurt every major company whose name is on
the signs at your corner gas station. ;

In closing, I and my fellow Alliance members are proud stewards of the lands and waters in
which we operate and provide the energy that makes the economy, and the world, go-round. We
proudly supply products and byproducts that have given the world a way of life that would not
exist otherwise, We understand and support the need and vitally important role of state-based
regulation of emissions as well as other facets of our industry. The current successful state-based
framework is where oversight and enforcement should remain.

I would be happy to answer your questions.

Thank you.
48

Written Testimony of Lishan Aklog M.D.

House Committee on Small Business Hearing “Burdensome
Regulations: Examining the Impact of EPA Regulations on Main Street”

Wednesday, February 14, 2024
10:00 a.m. ET

Chairman Williams, Ranking Member Velazquez, and members of the committee. Thank you for
inviting me to testify today.

My name is Dr. Lishan Aklog. | am a heart surgeon, medical technology innovator, entrepreneur,
and small public company chief executive.

Last July, | was honored to testify before the House Energy and Commerce Subcommittee on
Health on the importance of transparency and predictability in Medicare coverage of
breakthrough medical technologies, including the unique burdens faced by small innovative
companies in the current reimbursement landscape.

My testimony today shares many of the same underlying themes but focuses on the challenges
companies such as mine will face, and the substantial harm for the patients we serve, if we
don’t get the rules right surrounding medical device sterilization that EPA is currently proposing.

Industry supports an update to these rules regulating ethylene oxide sterilization, the primary
mode of sterilization for the many billions of medical devices produced and used every year.
However, these proposals as written, are projected to greatly reduce sterilization capacity for
lifesaving and life-enhancing medical devices which means a reduction in patient access to care.

To be. clear, the industry supports an update to the rules but it must be done carefully and in
close coordination with FDA and medical device experts.

As | did at the prior hearing, | hope to offer an enlightening perspective on the issue at hand,
both as a surgeon, who used such critical devices to care for patients every day for over twenty
years, and as a medtech chief executive who is developing and commercializing such devices
today. Let me note from the onset that | am not an expert on environmental science, toxicology,
sterilization technology, or the deeper policy dimensions of this issue. | do, however, have a
working understanding of the projected consequences of the proposed regulations, and hope to
provide some useful context as a small company executive and heart surgeon,

Let me start with a simple truth: medical technology innovation has provided us with novel
devices which reduce the burden of disease, relieve suffering, and save millions of lives each
year, That is a fact. | chose to transition from heart surgeon to medical technology innovator and
executive precisely because | appreciated that | could apply innovation to impact patients on a
49

larger scale than | could as an individual practitioner. The majority of medical technology
innovation happens at small companies such as mine. Small companies comprise approximately
eighty percent of the medical technology industry.

Governmental action.can have a significant impact, both positive and negative,.on the
development of, and access to, innovative medical technology products. For example,
governmental funding of basic science research often sows the critical early seeds for
innovation. Nondilutive funding from SBIR and STTR grants can offer a lifeline to early stage
smail companies. | commend the Committee for helping to shepherd reauthorization of these
programs in 2022. R&D expensing tax provisions are another important tool to foster
innovation. | commend the House for including such provisions in the recently passed tax relief
bill and hope the Senate will follow suit. ° ,

Finally, legislative reforms which seek to increase transparency and predictability along the path
to Medicare coverage of breakthrough devices would be a powerful stimulus to innovation. |
was pleased that H.R. 1691, the subject of my testimony last summer, made it out of committee
and | am hopeful that it will eventually become law.

Diverse governmental actions have great potential to positively impact innovation and equitable
patient access to lifesaving and life-enhancing products. In contrast, today’s hearing addresses a
proposed governmental action that has just as great, if not greater, potential to have a negative
impact for our healthcare system and patients we serve if not done correctly. They could stifle
development of new innovative products and adversely impact, in a dramatic way, the supply
chain of existing life-saving products, put millions of patients at risk of delayed care and even
death. This may sound like hyperbole, but | can assure you that it is not.

The reason that some provisions in this regulation, as well-intended as they might be, have the
potential to create such issues is that sterilization lies at the very heart of medical device
development and production.

When a company such as mine seeks FDA regulatory clearance of an innovative medical device,
it must design, verify and validate the often-complex processes required to manufacture such a
device. One of the most time-consuming and costly steps leading up to FDA submission is
rigorously documenting that the sterilization process works to perfection for that specific
product.

We must show that our final product remains sterile during its rated shelf life, posing zero
infectious risk to the patient. We must also show that the process of sterilizing, packaging and
storing our product does not damage or impair the function of what are often complex,
intricately assembled structures packaged in single-use kits.

This is more difficult than it may sound. Sterilization techniques which use extreme heat or
radiation to kill microbes can damage intricate components or fail to penetrate the inner parts
of a complex assembly. The anti-microbial gas ethylene oxide, however, can penetrate the
50

packaging as well as every nook and cranny of the device, sterilizing it without damaging its
structure or function. Ethylene oxide sterilization has emerged as the most effective, and in
most cases the only, currently available technique to sterilize the majority of medical devices,
and the vast majority of complex, life-saving devices.

Let me offer an.example from my direct experience as a heart surgeon. Every year, nearly a
million patients undergo life-saving heart valve replacement surgery. The implanted artificial
valves, designed to open and close hundreds of millions of times over several decades, are
marvels of modern medical technology, incorporating metal, plastic, woven fabric and biologic
tissue in a complex, intricate structure. The majority of heart valve replacement procedures are
now performed using catheter techniques without the need for open surgery, with even more
ingenious and complex constructions than surgically implanted valves.

An artificial heart valve infection is a catastrophic, and frequently fatal, complication, so these
devices must be perfectly sterile. There is zero margin for error. The only available technique to
sterilize artificial heart valves and the kits which are used to implant them is ethylene oxide. The
plastic and biologic components of the artificial valve cannot tolerate exposure to heat or
radiation. The catheter components have tiny internal channels extending over several feet,
called lumens, which accommodate guidewires and fluids. The only currently available
sterilizing gas which can penetrate a long catheter lumen is ethylene oxide.

It is my understanding that a large percentage of heart valves are sterilized at a single facility.
Any significant disruption in this facility’s capacity to sterilize artificial heart valves would have a
devastating effect on hundreds of thousands of patients whose lives depend on them. | cannot
even fathom the impact that the sudden closure of this facility, even temporarily, would have.
There is no question that many patients would die.

Of course, this is just one example that happens to resonate with me as someone who
performed heart surgery for many years. Every year, tens of millions of surgical procedures are
performed in this country, from relatively simple biopsies to the most complex and intricate
open-heart surgeries. The vast majority use devices and/or surgical kits sterilized with ethylene
oxide. Step out of the operating room to the intensive care unit, or any patient care area for that
matter, and ethylene oxide sterilized devices and kits are literally everywhere.

| would now like to shift to the central role sterilization, and ethylene oxide sterilization in
particular, has played, and continues to play, in my role as a medical technology innovator,
entrepreneur and chief executive of a small, innovative medical technology company. Fifteen
years ago, my partners and | founded our first company while | was still a practicing heart
surgeon. We invented, developed and commercialized a life-saving cardiovascular device which
has saved many thousands of lives. The device, which was acquired by a larger medical device
company ten years ago, is called AngioVac® and is now the standard of care to treat a deadly
type of heart valve infection without the need for highly invasive open surgery. It consists of two
separately packaged parts, each of which is sterilized using the exact same ethylene oxide
51

process we meticulously verified and validated many years ago. Any disruptions in access to
ethylene oxide sterilization would immediately impact the often gravely ill patients who depend
on AngioVac.

Today, | proudly serve as Chairman and Chief Executive of PAVmed (Nasdaq: PAVM), a small
diversified commercial-stage medical technology company which | co-founded, and its
subsidiaries Lucid Diagnostics Inc. (Nasdaq: LUCD), a cancer prevention company, and privately
held Veris Health Inc., a digital cancer care company. PAVmed and its subsidiaries have a
portfolio of innovative medical technologies in various stages of development and
commercialization which require ethylene oxide sterilization. We will or already have deployed
substantial resources, precious financial and human capital for a small company, to complete
the verification and validation processes necessary to receive FDA clearance and offer these
innovative technologies for the benefit of patients.

Our experience commercializing one of our more impactful and innovative products, Lucid
Diagnostics’ EsoCheck® Esophageal Cell Collection Device, nicely illustrates the unique
challenges small innovative companies face navigating the existing sterilization landscape and
the devastating impact acute reductions in sterilization capacity will have on our businesses and
the patients we serve. Lucid Diagnostics commercializes the groundbreaking EsoGuard®
Esophageal DNA Test—the first and only molecular diagnostic test that can accurately detect an
early stage precancer, specifically esophageal precancer, the precursor to highly lethal
esophageal cancer which kills over 16,000 Americans a year. :

Each of these tragic deaths could have been prevented if esophageal precancer had been
detected using our EsoGuard test before cancer develops. This requires collecting cells from the
lower esophagus, near the stomach, by some noninvasive means which eliminates the need for
complex and invasive upper gastrointestinal endoscopy.

EsoCheck is a deceptively simple but powerfully innovative tool which allows just that-—precise
targeted collection of lower esophageal cells performed in a doctor’s office. The patient
swallows a vitamin-sized capsule tethered to a thin catheter. A small balloon gently swabs cells
from the target area and the capsule protects the sample as the catheter is withdrawn. The
whole thing takes about two minutes and doesn’t require any anesthesia or sedation.
EsoCheck’s gentle approach to noninvasive cell collection is a dramatic and elegant
improvement over an older, cruder technology which involves dragging a Brillo pad-like sponge
on a string and indiscriminately scraping cells from the stomach, esophagus and mouth in an
untargeted fashion.

We licensed the EsoGuard and EsoCheck technologies from a major academic medical center
and advanced the EsoCheck cell collection device through FDA clearance and subsequent
commercial launch. Over ten thousand patients have undergone EsoCheck cell collection and
successful EsoGuard esophageal precancer testing, as part of our early assault on the scourge of
esophageal cancer. The FDA clearance required that EsoCheck be delivered as a sterile device to
52

assure that the sample is not seeded with contaminant DNA which could interfere with the
molecular diagnostic test. As a catheter device with a long, tiny lumen, ethylene oxide was and
remains EsoCheck’s only sterilization option.

We quickly learned that manufacturing a device sterilized with ethylene oxide was uniquely
challenging for a small company as a result of limited nationwide sterilization capacity. Large
companies can, and often do, bring ethylene oxide sterilization in-house. Small companies do
not have that option and are dependent on a small number of third-party sterilization
companies, with limited overall capacity. Not surprisingly, small companies such as ours are
their lowest priority customers and we began to experience perpetual threats to our supply
chain as demand for EsoCheck grew. ;

We soon realized that as difficult as our supply chain challenges were, there was a real risk of
things getting much, much worse as result of potentially dramatic cuts in already limited
sterilization capacity. In order to mitigate this risk, we made the difficult decision to proactively
deploy precious resources, including capital, to resubmit EsoCheck to the FDA as nonsterile
device. This required extensive additional testing to confirm that eliminating the sterilization
step did not adversely affect the performance of the device or the EsoGuard molecular test
itself. Fortunately, the testing went well and we were eventually granted a new FDA clearance
for EsoCheck as a nonsterile device.

All remain at severe risk of encountering supply chain disruptions if the proposed regulations
move forward as proposed. We need to get these rules right.

Although, as | noted in my opening, | am neither a policy nor technical expert on ethylene oxide
sterilization, | am, as the title of this hearing alludes to, a “Main Street” small company medical
technology company executive who has studied the issue in some depth and is alarmed at the
likelihood that pending EPA proposals will have a devastating effect on patient care nationwide
as they are currently proposed.

| will also note that | am first and foremost a physician and, incidentally, a member of a family
recently devastated by a cancer death, No one in this room is more committed than | am to
prevent cancer and cancer deaths. It is literally the sole mission of Lucid Diagnostics which
occupies the vast majority of my professional time.

As a first-generation American who fled political violence in Ethiopia over forty years ago, | have
enormous faith that this great country, which has given me boundless opportunities, can apply
technology and common-sense solutions to address its challenges.

Surgeons are known for their bluntness, so let me be blunt. The EPA regulations on device
sterilization require the surgical precision of a scalpel. There are a variety of sensible, targeted,
and scalable reforms to ethylene oxide sterilization regulation which would not risk patient
access or medical device sterilization capacity. We can keep communities safe and lifesaving
medical equipment available for patients.
53

Again, the industry supports an update to the rules, and we appreciate our ongoing
collaboration with EPA on a thoughtful rule but these concerns must be addressed before the
rules are finalized.

limplore this Committee, and Congress more broadly, to urgently work with the Executive
branch and ensure we get this rule right. We all share the same goal—of ensuing patients have
access to critical and lifesaving technologies they need.

Thank you very much for this opportunity and for your attention.
54

HEARING BEFORE THE HOUSE COMMITTEE ON SMALL BUSINESS
February 14, 2024

_ TESTIMONY OF MICHAEL GREEN, SPECIAL ADVISOR ON CLIMATE AND
ENERGY, AMERICAN SUSTAINABLE BUSINESS NETWORK

Chairman Roger Williams, Ranking Member Nydia Velazquez, and fellow Committee
Members, I welcome the opportunity to engage with your committee to discuss the nature of
regulatory policies coming from the Environmental Protection Agency and their impact on
mainstreet business. Today I have the opportunity to represent the American Sustainable
Business Network and our hundreds of businesses spread across the country. I also have the
opportunity to speak to you from the unique perspective of being a small business owner that is

located on our community's main street in Woodstock, Vermont.

I would like to start with sharing the experiences of our community this past summer
when a series of irregular weather events caused the second 100-year flooding event in the past
15 years. Between July 10th and 11th 2023, we had 9 inches of rainfall on the Green Mountain
Spine. The waters rushed down and inundated our village causing widespread damage to our
businesses and homes. My family was fortunate to be spared the devastation experienced by
several of my neighbors, but many businesses in our community were impacted by this event.
On the morning of the 1th, business owners across the state woke up to complete destruction as
several communities were completely cut off from rescue services with roads. sucked into the

raging rapids.

This experience is not unique to Vermont. This is the same story for small businesses
55

across the country as we continue to learn to adapt to our ever changing climate. We know that
small businesses are disproportionately impacted by the threats of climate change! due to their
limited resources to absorb financial shocks from catastrophic events. Without the ability to
relocate their brick and mortar businesses, being locked into less diversified supply chains, and
often unable to compete with larger corporations in the global marketplace, our small businesses
experience a heightened vulnerability to the threats of the climate crisis. A study by the Federal
Emergency Management Agency (FEMA) highlights that nearly 40% of small businesses never

reopen following a disaster”, underscoring the urgent need for supportive climate regulations.

Businesses are not only feeling the impact of the climate crisis through major flooding
events; many businesses are also forced to shutter their doors because of extreme heat and poor
air quality. The impacts of unchecked localized air pollutants have an impact on our workforce,
customers and communities as a whole. Strong EPA regulations such as the recent final rule on
Soot’ play a crucial role in safeguarding public health, reducing pollution-related illnesses, and
lowering healthcare costs. For small businesses, healthier communities translate to reduced sick
days, increased productivity, and a stronger consumer base. Research indicates that for every
dollar spent on air pollution control, approximately $30* in health benefits is realized,

demonstrating the economic viability of environmental regulations.

A 2023 report by the American Lung Association found that 36% of Americans—119.6
million people—still live in places with failing grades for unhealthy levels of ozone or

particulate pollution’. The same report found that the number of people living in counties with

' https://hbr.org/2016/1 l/small-and-young-busi are-especially-vul le-to-extr ther

2 , bets: //www.cnbe.com/2017/09/16/hurricane-watch-40- percent-of- small- buenuen-dont-reemencafier a-disaster. html
hitpsy/wrworasbnetwork org/media- : /stat t i inable-busi work-epa-national-ambient-air
~quality

* https:/Avww.epa.gov/sites/default/files/20 15-07/documents/factsheet.pdf
5 https://www.lung.org/research/sota/key-findings
56

failing grades for daily spikes in deadly particle pollution was 63.7 million, the most ever
reported under the current national standard. The impact from air pollution on our business
community is real, as the workforce in these heavily impacted communities are unable to
participate due to sick days, increased pulmonary disease or having to care for a loved one. By
fostering a healthier community, small businesses see a direct benefit in the form of a more
productive workforce and reduced healthcare expenses. The regulations put forward by the
Environmental Protection Agency work to level this playing field and create opportunities for

our small businesses to be a part of the solution.

Often, small businesses do not have the ability to force their will on the market like
larger corporate competitors might. The EPA has done a good job of taking these matters into
consideration when constructing their rulemaking process, engaging with our business leaders®

and taking their opinions into consideration when drafting final rules and regulations.

Attached to my testimony, I have included testimony and calls to action from the
hundreds of businesses that we have worked directly with at ASBN. This demonstrates our small
business commitment to working with the EPA and their regulatory process. For almost two
decades, we have been active in supporting a robust rulemaking process that supports scientific
backed policies. The attachment includes hundreds of small businesses across the nation that
have sent letters in support of recent EPA work to regulate dangerous pollution from mercury,
carbon, methane and soot. These businesses acknowledge the impact that these pollutants have
on their local communities and also recognize that the source of these pollutants is not the small

business community but instead the result of business from large out-of-state corporate polluters.

6

https://www.epa.gov/newsreleases/epa-reaffirms-commitment-supporting-small-businesses-during-national-small-busi
ness-0
57

Small businesses are smart enough to not pollute the community of which they are an integral

part.

EPA regulations often lead to significant shifts in market dynamics, incentivizing
companies to develop and adopt cleaner technologies and practices. Small businesses are at the
end of the issue and only see the harmful impacts of the unregulated market. These shifts towards
cleaner and more efficient outcomes create better outcomes for small businesses by aligning the

market with a healthier environment and often more efficient product choices.

There are several examples where EPA regulations have moved markets towards cleaner
solutions that yielded economic opportunity. For instance, the The Good Neighbor Plan has
guaranteed that companies are not impacted by cross-state pollution and the impact it may have
cross state borders. Not only does this support the local community and downwind communities,
it also guarantees that neighboring states don't become sacrificed due to lack of regulations from

a neighboring state.

One example that is important to many of the communities across New York, New
Hampshire and Maine is the Clean Air Act’s Acid Rain and Mercury and Toxic Substances
(MATS) programs. Through technical support, incentive structures, and a continued updating of
these important policies, the EPA has worked with power plants to reduce their SO2 NOX and
mercury emissions, a primary cause of acid rain and detriments to public health. These programs
have led to significant investments in cleaner technologies and practices. Small businesses are
often not implicated by the policy, since they are not large point source emitters but do stand to

benefit from the end results.
58

One example of the ability of EPA regulatory policy moving markets in favor of small
businesses is the EPA energy star program. This voluntary scheme promotes energy efficiency in
products, homes, and businesses and is a program that I would imagine many of the committee
members participate in through purchasing lower cost alternative home and office appliances. It
is difficult to find a business or home in America that has not reduced energy costs through
investing in things like energy efficient light bulbs. Manufacturers are incentivized to produce
more energy-efficient products to receive the Energy Star label, which is recognized by
consumers as a mark of energy efficiency. This program has significantly shifted the market
towards energy-efficient appliances, lighting, and buildings’ , reducing costs to small businesses

and homes alike.

Another example of the EPA regulatory framework creating markets for small businesses
is the Renewable Fuel Standard which requires a certain volume of renewable fuel to replace or"
reduce the quantity of petroleum-based transportation fuel. This has significantly boosted the
biofuel market’, encouraging the development of bioethanol and biodiesel industries. This has
been a critical market for US energy supply and supports the economic opportunity for farmers

in states like Ohio, Michigan and Minnisota’.

EPA regulations have often been a catalyst for innovation, driving both large and small
businesses to develop, adopt, and market environmentally friendly technologies and practices.
Small businesses, in particular, have benefited from these regulations in several ways, as they

can be more nimble and innovative in responding to regulatory requirements.

bs.

Fuel,from%20feedstocks%20other%20than%20cornstarch.
59

A clear example of this is regulations aimed at reducing waste and promoting energy
efficiency which have led to a surge in demand for green building materials. Small businesses
specializing in the production of sustainable building materials or offering green construction
services have experienced growth as a result. For instance, small businesses that produce
low-VOC (Volatile Organic Compound) paints and energy-efficient lighting have tapped into

markets created by environmental standards.

EPA's regulations under the Clean Water Act have prompted innovation in water
purification and stormwater management. Small businesses that develop and offer advanced
filtration systems, rainwater harvesting technologies, and eco-friendly drainage solutions have
benefited from the increased demand for technologies that help industries comply with discharge

standards.

One of the areas of growth that has been the most beneficial to businesses and
communities alike is technologies that support the measurement and reporting of localized air
pollutants. This growing industry has helped make regulations smarter through the use of
real-time technologies and put more information into the hands of decision makers. Small
businesses that invent and manufacture emission control technologies, such as scrubbers for
industrial smokestacks or catalytic converters for vehicles, have found new opportunities as a
result of strengthening air quality standards. These businesses often lead in providing

cost-effective and efficient solutions tailored to the needs of specific industries.

Lastly, no industry may have benefited from this more than the US Energy Industry.

Innovation as a response to regulation over dirty fuel types has played an integral role in
60

creating the cost parity between new energy systems’® and antiquated fuels that drive the climate
crisis. The push towards renewable energy, partly driven by the EPA's performance setting
regulation as well as carbon standards, has opened up markets! for small businesses involved in
solar, wind, and other renewable energy technologies. Additionally, small businesses that offer
energy audit services or energy management solutions help other businesses reduce energy

consumption and comply with regulations, fostering a market for energy efficiency services.

These examples demonstrate how EPA regulations have not only worked to protect the
environment and public health but have also encouraged entrepreneurial activity and innovation
among small businesses. By addressing environmental challenges, these businesses not only

contribute to sustainability but also create new industries and job opportunities.

Main street businesses are often the backbone of their local economy, especially in small .
towns and rural communities across the country. Business owners are often compelled to pursue
decisions that don’t have negative impacts in their own community fabric. EPA regulations aim
to address environmental and public health issues by targeting the most significant sources of
pollution, which are frequently large industrial facilities and power plants, not main street
businesses. By focusing on these major polluters, the regulations can inadvertently level the

playing field for small businesses in several ways.

One way in which the EPA manages the regulatory burden and also levels the playing
field is setting policy based on the overall amount of pollution, waste or hazardous material in

which a company generates. It is often the case that small main street businesses are not the large

ules.pdf
61

industrial sites that host and manage these pollutants, An example of this is how the EPA
classifies hazardous waste generators into categories based on the amount of waste they produce,
with different regulations applying to each category. Large quantity generators face more
stringent regulations and reporting requirements than small quantity or very small quantity
generators. This distinction ensures that small businesses generating less waste have fewer
regulatory hurdles, reducing the operational and compliance costs compared to those faced by

larger companies.

These examples show how EPA regulations are designed to mitigate environmental and
health risks by focusing on the largest contributors to pollution, which often results in a
regulatory framework that is inherently more focussed on large corporations, not main strect
businesses. Our main street businesses understand the importance of strengthening our clean air
and water standards. We need healthy communities, a dependable workforce, and an environment
that allows our businesses to thrive in place. Working with the EPA, we have an opportunity to sit
at the table and share the stories and experiences from our first hand knowledge. We appreciate
the opportunity that this committee has created to further engage in the process and hope that
future conversations will focus on the negative impacts that climate change and public health can

have on our business community.
62
ic Biography:

Michael Green leads ASBN Climate and Energy Working group and assists with the
organization's overall strategy on climate policy. Michael lives in Vermont where he works for an
environmental services company, Native, A Public Benefit Corporation. In 2016, Michael was
presented the Champion of Change Award by President Obama for his commitment to climate
change as an equity issue at the White House.

Michael currently serves on several nonprofit boards and acts as an advisor on climate
policy for government agencies and nonprofits. His passion for protecting our climate stems from
his small mountain community and adoration of the great outdoors. Outside of the office, he can

often be found roaming the nearest mountains on his bicycle, skis or in his hiking boots.
63

JAVA, Sustainable

NAV Business
NY Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Shanti Holloway and I’m from Durham, NC. | am writing to express my, and my organization,
ASBN’s, strong support for the Biden administration’s proposed standards to cut climate pollution from
coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. EPA’s proposal is a critically important step forward, providing a
clear end point for where the industry needs to get to as well as pathways to modernize how we
produce power in this country. Listen to scientists’ warnings about the urgent need for climate action
and the voices of those living near power plants most impacted by their emissions, which are
disproportionately low-income and communities of color. By providing several different opportunities
for compliance and multiple financial incentives, power plants will have what they need to move
forward with rapid emission reduction. | encourage the agency to move forward with this proposal and
work to achieve greater cuts to pollution from more sources on the fastest possible timelines. This
proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma
attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and
public health benefits. It is critical that in tandem with this standard, the EPA and the entire Biden
administration follow through on critical protections for communities that have historically borne the
brunt of deadly pollution from power plants and may continue to face power plant pollution. Our
climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
64

BS. American
NN Sustainable

NY etwork

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Chad Speight and I’m from Madison, WI. | am writing to express my, and my organization,
Chads Design Build’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
65

Js. American
V\ZANIN Sustainable

YAU Business
ey Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Kristine Waldren and I’m from Cypress, CA. | am writing to express my,.and my organization,
ECOS’s, strong support for the Biden administration’s proposed standards to cut climate pollution from
coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. EPA’s proposal is a critically important step forward, providing a
clear end point for where the industry needs to get to as well as pathways to modernize how we
produce power in this country. Listen to scientists’ warnings about the urgent need for climate action
and the voices of those living near power plants most impacted by their emissions, which are
disproportionately low-income and communities of color. By providing several different opportunities
for compliance and multiple financial incentives, power plants will have what they need to move
forward with rapid emission reduction. | encourage the agency to move forward with this proposal and
work to achieve greater cuts to pollution from more sources on the fastest possible timelines. This
proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma
attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and
public health benefits. It is critical that in tandem with this standard, the EPA and the entire Biden
administration follow through on critical protections for communities that have historically borne the
brunt of deadly pollution from power plants and may continue to face power plant pollution. Our
climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
66

=. American
, Sustainable

ps
SN

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Richard Lawton and I’m from Point Pleasant Beach, NJ. |am writing to express my, and my
organization, NJ Sustainable Business Council’s, strong support for the Biden administration’s proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically
important step forward, providing a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. Listen to scientists’ warnings about the
urgent need for climate action and the voices of those living near power plants most impacted by their
emissions, which are disproportionately low-income and communities of color. By providing several
different opportunities for compliance and multiple financial incentives, power plants will have what
they need to move forward with rapid emission reduction. | encourage the agency to move forward with
this proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
67

J. American

WAY Business
NOY Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Michelle Hirons and I’m from San Francisco, CA. | am writing to express my, and my
organization, HigherRing’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
68

BS. American
yy Business

Be” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Liz Rubin and I’m from New York, NY. | am writing to express my, and my organization,
Ecodeo’s, strong support for the Biden administration’s proposed standards to cut climate pollution
from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. EPA’s proposal is a critically important step forward, providing a
clear end point for where the industry needs to get to as well as pathways to modernize how we
produce power in this country. Listen to scientists’ warnings about the urgent need for climate action
and the voices of those living near power plants most impacted by their emissions, which are
disproportionately low-income and communities of color. By providing several different opportunities
for compliance and multiple financial incentives, power plants will have what they need to move
forward with rapid emission reduction. | encourage the agency to move forward with this proposal and
work to achieve greater cuts to pollution from more sources on the fastest possible timelines. This
proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma
attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and
public health benefits. It is critical that in tandem with this standard, the EPA and the entire Biden
administration follow through on critical protections for communities that have historically borne the
brunt of deadly pollution from power plants and may continue to face power plant pollution. Our
climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
69

Js American

Vay)’ Business
oy Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Charlie Garlow and I'm from Rehoboth Beach, DE. | am writing to express my, and my
organization, DEEVA DE Electric Vehicle Association's, strong support for the Biden administration’s
proposed standards to cut climate pollution from coal- and natural gas-fired power plants. As we know,
fossil fuel-fired power plants are one of the largest sources of carbon pollution, using the air our
communities and businesses are dependent upon as a dumping ground for far too long. EPA’s proposal
is a critically important step forward, providing a clear end point for where the industry needs to get to
as well as pathways to modernize how we produce power in this country. Listen to scientists’ warnings
about the urgent need for climate action and the voices of those living near power plants most impacted
by their emissions, which are disproportionately low-income and communities of color. By providing
several different opportunities for compliance and multiple financial incentives, power plants will have
what they need to move forward with rapid emission reduction. | encourage the agency to move
forward with this proposal and work to achieve greater cuts to pollution from more sources on the
fastest possible timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER
visits, more than 300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing
up to $85 billion in net climate and public health benefits. It is critical that in tandem with this standard,
the EPA and the entire Biden administration follow through on critical protections for communities that
have historically borne the brunt of deadly pollution from power plants and may continue to face power
plant pollution. Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible
standards to cut climate pollution from power plants
70

ca) Sustainable
usiness

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Mark Canright and I’m from Asbury, NJ. | am writing to express my, and my organization,
Comeback Farm Organic Produce’s, strong support for the Biden administration’s proposed standards to
cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities. that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
71

SS. American
V\NIN Sustainable

WANA Business
NOL Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Ciean
Energy Rule EPA-HQ-OAR-2023-0072

My name is arielle !lewellyn and I’m from Alameda, CA. | am writing to express my, and my organization,
EBNG’s, strong support for the Biden administration’s proposed standards to cut climate pollution from
coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. EPA’s proposal is a critically important step forward, providing a
clear end point for where the industry needs to get to as well as pathways to modernize how we
produce power in this country. Listen to scientists’ warnings about the urgent need for climate action
and the voices of those living near power plants most impacted by their emissions, which are
disproportionately low-income and communities of color. By providing several different opportunities
for compliance and multiple financial incentives, power plants will have what they need to move
forward with rapid emission reduction. | encourage the agency to move forward with this proposal and
work to achieve greater cuts to pollution from more sources on the fastest possible timelines. This
proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma
attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and
public health benefits. It is critical that in tandem with this standard, the EPA and the entire Biden
administration follow through on critical protections for communities that have historically borne the
brunt of deadly pollution from power plants and may continue to face power plant pollution. Our
climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
72

J. American

NAY Business
NY Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Mitch Ratcliffe and I’m from Lakewood, WA. | am writing to express my, and my _
organization, Earth911 Inc.’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
73

—

BS. American
SA s Sustainable

Vay’ Business

Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Bill McClain and (’m from Bainbridge Island, WA. | am writing to express my, and my
organization, Clean & Prosperous American's, strong support for the Biden administration's proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically
important step forward, providing a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. Listen to scientists’ warnings about the
urgent need for climate action and the voices of those living near power plants most impacted by their
emissions, which are disproportionately low-income and communities of color. By providing several
different opportunities for compliance and multiple financial incentives, power plants will have what
they need to move forward with rapid emission reduction. | encourage the agency to move forward with
this proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
74

VOKN Sustainable

WAH) Business
Veg Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Motthida Chin and I’m from Seattle, WA. | am writing to express my, and my organization,
Motthida Chin, LLC’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
75

V\ZNIN Sustainable
V2’ Business
Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Emily Snyder and I’m from New Orleans, LA. | am writing to express my, and my
organization, Urban Conservancy’s, strong support for the Biden administration’s proposed standards to
cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
76

JZ. American

V\/NIN Sustainable

WAY Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA~-HQ-OAR-2023-0072

My name is Keyanna Silverman and I’m from Detroit, MI. | am writing to express my, and my
organization, Detroit Community Wealth Fund’s, strong support for the Biden administration’s proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically
important step forward, providing a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. Listen to scientists’ warnings about the
urgent need for climate action and the voices of those living near power plants most impacted by their
emissions, which are disproportionately low-income and communities of color. By providing several
different opportunities for compliance and multiple financial incentives, power plants will have what
they need to move forward with rapid emission reduction. | encourage the agency to move forward with
this proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
77
245%. American
ea Sustainable
usiness
NI Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Virginia Auster and t’m from Norwalk, CT. | am writing to express my, and my organization,
Wilton Quaker Meeting’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
78

AVASSIN, Sustainable

WA) Business
NOY Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Becky Reimbold and I’m from South Bend, IN. | am writing to express my, and my
organization, Just Goods’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
79

—

BS. American
NIN Sustainable

\/' Business
oy Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Mark Hayduke Grenard and I’m from Phoenix, AZ. | am writing to express my, and my
organization, Mark's Bookmark Bookseller's, strong support for the Biden administration’s proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically
important step forward, providing a clear end point for where the industry needs to get to as weil as
pathways to modernize how we produce power in this country. Listen to scientists’ warnings about the
urgent need for climate action and the voices of those living near power plants most impacted by their
emissions, which are disproportionately low-income and communities of color. By providing several
different opportunities for compliance and multiple financial incentives, power plants will have what
they need to move forward with rapid emission reduction. | encourage the agency to move forward with
this proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
80

= American

DN Sustainable

j
WAZA Business
NC Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072 .

My name is John Davies and I’m from Buena Park, CA. | am writing to express my, and my organization,
Avocado Green Brands’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
81

—

BS. American
) Sustainable

Ba’ Network

\

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Jerry Rivers and I’m from Roosevelt, NY. | am writing to express my, and my organization,
North American Climate, Conservation and Environment(NACCE)’s, strong support for the Biden
administration’s proposed standards to cut climate pollution from coal- and natural gas-fired power
plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon pollution,
using the air our communities and businesses are dependent upon as a dumping ground for far too

long. EPA’s proposal is a critically important step forward, providing a clear end point for where the
industry needs to get to as well as pathways to modernize how we produce power in this country. Listen
to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. By providing several different opportunities for compliance and multiple financial
incentives, power plants will have what they need to move forward with rapid emission reduction. |
encourage the agency to move forward with this proposal and work to achieve greater cuts to pollution
from more sources on the fastest possible timelines. This proposal would avoid 1,300 premature
deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and
66,000 lost work days providing up to $85 billion in net climate and public health benefits. It is critical
that in tandem with this standard, the EPA and the entire Biden administration follow through on critical
protections for communities that have historically borne the brunt of deadly pollution from power
plants and may continue to face power plant pollution. Our climate can’t wait. The EPA must act by early
2024 to finalize the strongest possible standards to cut climate pollution from power plants
82

—

S Sustainable
Business

4 p Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Dana Weintraub and I’m from Beaverton, OR. | am writing to express my, and my
organization, Evergreen Sustainability, LLC’s, strong support for the Biden administration's proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long: EPA’s proposal is a critically
important step forward, providing a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. Listen to scientists’ warnings about the
urgent need for climate action and the voices of those living near power plants most impacted by their
emissions, which are disproportionately low-income and communities of color. By providing several
different opportunities for compliance and multiple financial incentives, power plants will have what
they need to move forward with rapid emission reduction. | encourage the agency to move forward with
this proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
83

SEN American
V\ZANIN Sustainable

i
NV Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordabie Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Dr. Kakha NADIRADZE and |’m from Thilsi, GE-TB. | am writing to express my, and my
organization, Association for Farmers Rights Defense, AFRD’s, strong support for the Biden
administration’s proposed standards to cut climate pollution from coal- and natural gas-fired power
plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon pollution,
using the air our communities and businesses are dependent upon as a dumping ground for far too

long. EPA’s proposal is a critically important step forward, providing a clear end point for where the
industry needs to get to as well as pathways to modernize how we produce power in this country. Listen
to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. By providing several different opportunities for compliance and multiple financial
incentives, power plants will have what they need to move forward with rapid emission reduction. |
encourage the agency to move forward with this proposal and work to achieve greater cuts to pollution
from more sources on the fastest possible timelines. This proposal would avoid 1,300 premature
deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and
66,000 lost work days providing up to $85 billion in net climate and public health benefits. It is critical
that in tandem with this standard, the EPA and the entire Biden administration follow through on critical
protections for communities that have historically borne the brunt of deadly pollution from power
plants and may continue to face power plant pollution. Our climate can’t wait. The EPA must act by early
2024 to finalize the strongest possible standards to cut climate pollution from power plants
84

S25 American

CD Sustainable
usiness

NY Network

\

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is James Costello and I’m from Fairfax, CA. |am writing to express my, and my organization,
Green River Financial's, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
85

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Jared Meyers and I’m from Saint Petersburg, FL. | am writing to express my, and my
organization, Salt Palm Development’s, strong support for the Biden administration’s proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. EPA's proposal is a critically
important step forward, providing a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. Listen to scientists’ warnings about the
urgent need for climate action and the voices of those living near power plants most impacted by their
emissions, which are disproportionately low-income and communities of color. By providing several
different opportunities for compliance and multiple financial incentives, power plants will have what
they need to move forward with rapid emission reduction. | encourage the agency to move forward with
this proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
86

Ji. American
NAY)’ Business

“We” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Jared Meyers and I’m from Orlando, FL. | am writing to express my, and my organization,
Florida For Good’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
87

—

BS. American
KN Sustainable

iy Network

M

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Patricia Miller and I’m from Middletown, NJ. | am writing to express my, and my
organization, Middletown for Clean Energy’s, strong support for the Biden administration’s proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically
important step forward, providing a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. Listen to scientists’ warnings about the
urgent need for climate action and the voices of those living near power plants most impacted by their
emissions, which are disproportionately low-income and communities of color. By providing several
different opportunities for compliance and multiple financial incentives, power plants will have what
they need to move forward with rapid emission reduction. | encourage the agency to move forward with
this proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
88

V\/ANIN Sustainable
\ IN

ey Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Shannon Bone and I’m from Charlotte, NC. | am writing to express my, and my organization,
New Leaf Paper’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines., This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. it is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
89

J. American
V\ ANIM Sustainable

N27) Business
NY Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Jenny Morgan and I'm from Seattle, WA. | am writing to express my, and my organization,
Tradewater’s, strong support for the Biden administration’s proposed standards to cut climate pollution
from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. EPA’s proposal is a critically important step forward, providing a
clear end point for where the industry needs to get to as well as pathways to modernize how we
produce power in this country. Listen to scientists’ warnings about the urgent need for climate action
and the voices of those living near power plants most impacted by their emissions, which are
disproportionately low-income and communities of color. By providing several different opportunities
for compliance and multiple financial incentives, power plants will have what they need to move
forward with rapid emission reduction. | encourage the agency to move forward with this proposal and
work to achieve greater cuts to pollution from more sources on the fastest possible timelines. This
proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma
attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and
public health benefits. It is critical that in tandem with this standard, the EPA and the entire Biden
administration follow through on critical protections for communities that have historically borne the
brunt of deadly pollution from power plants and may continue to face power plant pollution. Our
climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
90

6. American

SY Sustainable
usiness

NO Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Leslie Samuelrich and I’m from Boston, MA. | am writing to express my, and my
organization, Green Century Funds’s, strong support for the Biden administration’s proposed standards
to cut climate pollution from coal- and natural gas-fired power plants, As we know, fossil fuel-fired
power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically
important step forward, providing a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. Listen to scientists’ warnings about the
urgent need for climate action and the voices of those living near power plants most impacted by their
emissions, which are disproportionately low-income and communities of color. By providing several
different opportunities for compliance and multiple financial incentives, power plants will have what
they need to move forward with rapid emission reduction. | encourage the agency to move forward with
this proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
91

VON Sustainable

Waza Business
ey Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is James Dawson and I’m from Davis, CA. |am writing to express my, and my organization,
James' Solar’s, strong support for the Biden administration’s proposed standards to cut climate pollution
from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. EPA’s proposal is a critically important step forward, providing a
clear end point for where the industry needs to get to as well as pathways to modernize how we
produce power in this country. Listen to scientists’ warnings about the urgent need for climate action
and the voices of those living near power plants most impacted by their emissions, which are
disproportionately low-income and communities of color. By providing several different opportunities
for compliance and multiple financial incentives, power plants will have what they need to move
forward with rapid emission reduction. | encourage the agency to move forward with this proposal and
work to achieve greater cuts to pollution from more sources on the fastest possible timelines. This
proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma
attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and
public health benefits. It is critical that in tandem with this standard, the EPA and the entire Biden
administration follow through on critical protections for communities that have historically borne the
brunt of deadly pollution from power plants and may continue to face power plant pollution. Our
climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
92

Seas American
V\ANIN Sustainable

7

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Sarah Gallagher and I’m from New York, NY. i am writing to express my, and my
organization, Upper Green Side’s, strong support for the Biden administration’s proposed standards to
cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
93

J245\. American

NAV Business
oy Network

Ava

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Fran Aguirre and I’m from Denver, CO. | am writing to express my, and my organization,
Unite North Metro Denver’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate. and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
94

ais American
V\ANIN Sustainable
‘Way Business

Ba’ Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Maiya Holliday and I’m from Truckee, CA. | am writing to express my, and my organization,
Mangrove Web’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
95

Ses American

oT Sustainable
usiness

ey Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Spencer Bruce and I’m from Brooklyn, NY. | am writing to express my, and my organization,
Climate Neutral’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
96

V\ANIN Sustainable

|
NC Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Aaron Ableman and I’m from El Sobrante, CA. | am writing to express my, and my
organization, Kindhumans’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
97

% American
VJ’ Business

i
\

7 Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Arielle Llewellyn and I’m from Alameda, CA. | am writing to express my, and my
organization, East Bay Natural Grocers’s, strong support for the Biden administration’s proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically
important step forward, providing a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. Listen to scientists’ warnings about the
urgent need for climate action and the voices of those living near power plants most impacted by their
emissions, which are disproportionately low-income and communities of color. By providing several
different opportunities for compliance and multiple financial incentives, power plants will have what
they need to move forward with rapid emission reduction. | encourage the agency to move forward with
this proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
98

BS. American
SA Sustainable

YAU)’ Business
oy Network

KK

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Hank Skade and I’m from Bend, OR. | am writing to express my, and my organization,
Tiburon Ventures, LLC’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
99

S26. American

usiness

NO Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Prasad Jaladi and I’m from Austin, TX. | am writing to express my, and my organization,
Suraksha’s, strong support for the Biden administration’s proposed standards to cut climate pollution
from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. EPA’s proposal is a critically important step forward, providing a
clear end point for where the industry needs to get to as well as. pathways to modernize how we
produce power in this country. Listen to scientists’ warnings about the urgent need for climate action
and the voices of those living near power plants most impacted by their emissions, which are
disproportionately low-income and communities of color. By providing several different opportunities
for compliance and multiple financial incentives, power plants will have what they need to move
forward with rapid emission reduction. | encourage the agency to move forward with this proposal and
work to achieve greater cuts to pollution from more sources on the fastest possible timelines. This
proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma
attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and
public health benefits. It is critical that in tandem with this standard, the EPA and the entire Biden
administration follow through on critical protections for communities that have historically borne the
brunt of deadly pollution from power plants and may continue to face power plant pollution. Our
climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
100

NAV)! Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is David Wilcox and I’m from Brookline, MA. | am writing to express my, and my organization,
ReachScale’s, strong support for the Biden administration’s proposed standards to cut climate pollution
from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. EPA’s proposal is a critically important step forward, providing a
clear end point for where the industry needs to get to as well as pathways to modernize how we
produce power in this country. Listen to scientists’ warnings about the urgent need for climate action
and the voices of those living near power plants most impacted by their emissions, which are
disproportionately low-income and communities of color. By providing several different opportunities
for compliance and multiple financial incentives, power plants will have what they neéd to move
forward with rapid emission reduction. | encourage the agency to move forward with this proposal and
work to achieve greater cuts to pollution from more sources on the fastest possible timelines. This
proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma
attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and
public health benefits. It is critical that in tandem with this standard, the EPA and the entire Biden
administration follow through on critical protections for communities that have historically borne the
brunt of deadly pollution from power plants and may continue to face power plant pollution. Our
climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
101

=. American

VAAN Sustainable

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Alexander Sexsmith and I’m from Tucson, AZ. | am writing to express my, and my
organization, Sexsmith Architects’s, strong support for the Biden administration’s proposed standards to
cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
102

AVA Sustaina ble

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is George LoCascio and I'm from Gardner, MA. | am writing to express my, and my
organization, MWCC’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
103

Jp. American
V\/ZNIN Sustainable

WANA) Business
NOI Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Miranda Pildes and I’m from Brooklyn, NY. | am writing to express my, and my organization,
Joyaux Marisol (Joyaux Corp)’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution,
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
104

—

ge. American
Van, Sustainable
NAY Business

7 Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is WILHELM REINDERS and I’m from Forest Hills, NY. | am writing to express my, and my
organization, SULA NYC’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
105

SE American

WAZ Business
Way Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Bob Bechtold and I’m from Ontario, NY. 1am writing to express my, and my organization,
HARBEC’s, strong support for the Biden administration’s proposed standards to cut climate pollution
from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. EPA’s proposal is a critically important step forward, providing a
clear end point for where the industry needs to get to as well as pathways to modernize how we
produce power in this country. Listen to scientists’ warnings about the urgent need for climate action
and the voices of those living near power plants most impacted by their emissions, which are
disproportionately low-income and communities of color. By providing several different opportunities
for compliance and multiple financial incentives, power plants will have what they need to move
forward with rapid emission reduction. | encourage the agency to move forward with this proposal and
work to achieve greater cuts to pollution from more sources on the fastest possible timelines. This
proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma
attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and
public health benefits. It is critical that in tandem with this standard, the EPA and the entire Biden
administration follow through on critical protections for communities that have historically borne the
brunt of deadly pollution from power plants and may continue to face power plant pollution. Our
climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
106

Ss American

IVAN, Sustainable

NAT Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Monica Dodi and I’m from Los Angeles, CA. | am writing to express my, and my organization,
The 22’s, strong support for the Biden administration’s proposed standards to cut climate pollution from
coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. EPA’s proposal is a critically important step forward, providing a
clear end point for where the industry needs to get to as well as pathways to modernize how we
produce power in this country. Listen to scientists’ warnings about the urgent need for climate action
and the voices of those living near power plants most impacted by their emissions, which are
disproportionately low-income and communities of color. By providing several different opportunities
for compliance and multiple financial incentives, power plants will have what they need to move
forward with rapid emission reduction. | encourage the agency to move forward with this proposal and
work to achieve greater cuts to pollution from more sources on the fastest possible timelines. This
proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma
attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and
public health benefits. It is critical that in tandem with this standard, the EPA and the entire Biden
administration follow through on critical protections for communities that have historically borne the
brunt of deadly pollution from power plants and may continue to face power plant pollution. Our
climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
107

=. American
NIN Sustainable
Avi’ Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Amy Bergman and I’m from Alexandria, VA. | am writing to express my, and my organization,
The Apothecary’s Daughter's, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
108

Ji American |
V\ANIN Sustainable

\

=

j
\

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Steven Adams and I’m from Viroqua, WI. | am writing to express my, and my organization,
Chrysalis Farm’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines, This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
109

V\ZNIN Sustainable
SAY) Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Corinne LaManna and I’m from Washington, DC. | am writing to express my, and my
organization, ASBN’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
110

Ss American

AS Sustainable
usiness

‘eer Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is sidney amster and I’m from Philadelphia, PA. | am writing to express my, and my
organization, SVC’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
111

cS Sustainable
usiness

ee Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Patrick Hughes and I’m from Dallas, TX. | am writing to express my, and my organization,
Pinnacle Coatings Group’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
112

Jas Ameri
AVASIN, Sustainable

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Sandra Stewart and I’m from San Francisco, CA. | am writing to express my, and my
organization, Thinkshift Communications’s, strong support for the Biden administration's proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the-air our communities and
businesses are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically
important step forward, providing a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. Listen to scientists’ warnings about the
urgent need for climate action and the voices of those living near power plants most impacted by their
emissions, which are disproportionately low-income and communities of color. By providing several
different opportunities for compliance and multiple financial incentives, power plants will have what
they need to move forward with rapid emission reduction. | encourage the agency to move forward with
this proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
113

CNA! Business
NY Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HO-OAR-2023-0072

My name is Mike Englert and I’m from Washington, DC. | am writing to express my, and my organization,
Eighty2degrees LLC’s, strong support for the Biden administration's proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
114

V\ANIN Sustainable

NOY Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Robert Taylor and I’m from Clearlake, CA. | am writing to express my, and my organization,
Konocti Senior Support’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
115

vay Sustainable
Business

AN

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Daniel OBrien and I’m from Milton, NY. | am writing to express my strong support for the
Biden administration’s proposed standards to cut climate pollution from coal- and natural gas-fired
power plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon
pollution, using the air our communities and businesses are dependent upon as a dumping ground for
far too long. EPA’s proposal is a critically important step forward, providing a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. By providing several different opportunities for compliance and multiple financial
incentives, power plants will have what they need to move forward with rapid emission reduction. |
encourage the agency to move forward with this proposal and work to achieve greater cuts to pollution
from more sources on the fastest possible timelines. This proposal would avoid 1,300 premature
deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and
66,000 lost work days providing up to $85 billion in net climate and public health benefits. It is critical
that in tandem with this standard, the EPA and the entire Biden administration follow through on critical
protections for communities that have historically borne the brunt of deadly pollution from power
plants and may continue to face power plant pollution. Our climate can’t wait. The EPA must act by early
2024 to finalize the strongest possible standards to cut climate pollution from power plants
116

S25. American
V\ANIN Sustainable

NOK Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Charles Wolfe and I’m from Sylmar, CA. | am writing to express my, and my organization, C.
Wolfe Software Engineering’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
117

ais American

Ba’ Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Storm Cunningham and I’m from Arlington, VA. | am writing to express my, and my
organization, RECONOMICS Institute’s, strong support for the Biden administration’s proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically
important step forward, providing a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. Listen to scientists’ warnings about the
urgent need for climate action and the voices of those living near power plants most impacted by their
emissions, which are disproportionately low-income and communities of color. By providing several
different opportunities for compliance and multiple financial incentives, power plants will have what
they need to move forward with rapid emission reduction. | encourage the agency to move forward with
this proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
118

—

IN Sustainable

WAH Business
Vee Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Jean Chagnon and I’m from New York, NY. | am writing to express my, and my organization,
udem’s, strong support for the Biden administration’s proposed standards to cut climate pollution from
coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. EPA’s proposal is a critically important step forward, providing a
clear end point for where the industry needs to get to as well as pathways to modernize how we
produce power in this country. Listen to scientists’ warnings about the urgent need for climate action
and the voices of those living near power plants most impacted by their emissions, which are
disproportionately low-income and communities of color. By providing several different opportunities
for compliance and multiple financial incentives, power plants will have what they need to move
forward with rapid emission reduction. | encourage the agency to move forward with this proposal and
work to achieve greater cuts to pollution from more sources on the fastest possible timelines. This
proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma
attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and
public health benefits. It is critical that in tandem with this standard, the EPA and the entire Biden
administration follow through on critical protections for communities that have historically borne the
brunt of deadly pollution from power plants and may continue to face power plant pollution. Our
climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
119

J. American

VON Sustainable
Way Business

Sey Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Lara Pearson and I’m from Incline Village, NV. | am writing to express my, and my
organization, Law Office of Lara Pearson Ltd, PBC d/b/a Brand Geek’s, strong support for the Biden
administration’s proposed standards to cut climate pollution from coal- and natural gas-fired power
plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon pollution,
using the air our communities and businesses are dependent upon as a dumping ground for far too
long. EPA’s proposal is a critically important step forward, providing a clear end point for where the
industry needs to get to as well as pathways to modernize how we produce power in this country. Listen
to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. By providing several different opportunities for compliance and multiple financial
incentives, power plants will have what they need to move forward with rapid emission reduction. |
encourage the agency to move forward with this proposal and work to achieve greater cuts to pollution
from more sources on the fastest possible timelines. This proposal would avoid 1,300 premature
deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and
66,000 lost work days providing up to $85 billion in net climate and public health benefits. It is critical
that in tandem with this standard, the EPA and the entire Biden administration follow through on critical
protections for communities that have historically borne the brunt of deadly pollution from power
plants and may continue to face power plant pollution. Our climate can’t wait. The EPA must act by early
2024 to finalize the strongest possible standards to cut climate pollution from power plants
120

—

BS. American
SA Sustainable

YAU) Business
Ba’ Network

\

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Adam Goettelman and I’m from Sturgeon Bay, Wi. | am writing to express my, and my
organization, Healthy Way Market's, strong support for the Biden administration’s proposed standards
to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired
power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically
important step forward, providing a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. Listen to scientists’ warnings about the
urgent need for climate action and the voices of those living near power plants most impacted by their
emissions, which are disproportionately low-income and communities of color. By providing several
different opportunities for compliance and multiple financial incentives, power plants will have what
they need to move forward with rapid emission reduction. | encourage the agency to move forward with
this proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net. climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
121

S245. American
AVASIN, Sustainable

WAZ Business
NO Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Hannah Lee and I’m from Madison, WI. | am writing to express my strong support for the
Biden administration’s proposed standards to cut climate pollution from coal- and natural gas-fired
power plants, As we know, fossil fuel-fired power plants are one of the largest sources of carbon
pollution, using the air our communities and businesses are dependent upon as a dumping ground for
far too long. EPA’s proposal is a critically important step forward, providing a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. By providing several different opportunities for compliance and multiple financial
incentives, power plants will have what they need to move forward with rapid emission reduction. |
encourage the agency to move forward with this proposal and work to achieve greater cuts to pollution
from more sources on the fastest possible timelines. This proposal would avoid 1,300 premature
deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and
66,000 lost work days providing up to $85 billion in net climate and public health benefits. It is critical
that in tandem with this standard, the EPA and the entire Biden administration follow through on critical
protections for communities that have historically borne the brunt of deadly pollution from power
plants and may continue to face power plant pollution. Our climate can’t wait. The EPA must act by early
2024 to finalize the strongest possible standards to cut climate pollution from power plants
122

\ American

“Sz” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Linda McNeel and I’m from Madison, WI. | am writing to express my, and my organization,
Bachman McNeel & Associates’s, strong support for the Biden administration’s proposed standards to
cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital.and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait, The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
SA Sustainable

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My-name is Rachel Duffy and I’m from Morrisville, VT. | am writing to express my, and my organization,
Peoples Academy’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This. proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants :
124

~ American
SN Sustainable
7’ Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Frank Scarpaci and I’m from San Diego, CA. ! am writing to express my, and my organization,
Vianova’s, strong support for the Biden administration’s proposed standards to cut climate pollution
from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. EPA’s proposal is a critically important step forward, providing a
clear end point for where the industry needs to get to as well as pathways to modernize how we
produce power in this country. Listen to scientists’ warnings about the urgent need for climate action
and the voices of those living near power plants most impacted by their emissions, which are
disproportionately low-income and communities of color. By providing several different opportunities
for compliance and multiple financial incentives, power plants will have what they need to move
forward with rapid emission reduction. | encourage the agency to move forward with this proposal and
work to achieve greater cuts to pollution from more sources on the fastest possible timelines. This
proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma
attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and
public health benefits. It is critical that in tandem with this standard, the EPA and the entire Biden
administration follow through on critical protections for communities that have historically borne the
brunt of deadly pollution from power plants and may continue to face power plant pollution. Our
climate can’t wait, The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
125

Sy Sustainable
| Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HO-OAR-2023-0072

My name is Lynette Miller and I’m from Madison, WI. | am writing to express my strong support for the
Biden administration’s proposed standards to cut climate pollution from coal- and natural gas-fired
power plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon
pollution, using the air our communities and businesses are dependent upon as a dumping ground for
far too long. EPA’s proposal is a critically important step forward, providing a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. By providing several different opportunities for compliance and multiple financial
incentives, power plants will have what they need to move forward with rapid emission reduction, |
encourage the agency to move forward with this proposal and work to achieve greater cuts to pollution
from more sources on the fastest possible timelines. This proposal would avoid 1,300 premature
deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and: __
66,000 lost work days providing up to $85 billion in net climate and public health benefits. It is critical
that in tandem with this standard, the EPA and the entire Biden administration follow through on critical
protections for communities that have historically borne the brunt of deadly pollution from power
plants and may continue to face power plant pollution. Our climate can’t wait. The EPA must act by early
2024 to finalize the strongest possible standards to cut climate pollution from power plants
126

American
, Sustainable
' Business
Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Mary Weyker and I’m from Racine, WI. | am writing to express my, and my organization,
Sisters of St Dominic’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net.climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the.brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
127

£2. American
ia SN Sustainable

ee Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Brian Caneda and I’m from North Charleston, SC. | am writing to express my strong support
for the Biden administration’s proposed standards to cut climate poilution from coal- and natural gas-
fired power plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon
pollution, using the air our communities and businesses are dependent upon as a dumping ground for
far too long. EPA’s proposal is a critically important step forward, providing a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. By providing several different opportunities for compliance and multiple financial
incentives, power plants will have what they need to move forward with rapid emission reduction. |
encourage the agency to move forward with this proposal and work to achieve greater cuts to pollution
from more sources on the fastest possible timelines. This proposal would avoid 1,300 premature
deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and
66,000 lost work days providing up to $85 billion in net climate and public health benefits. It is critical
that in tandem with this standard, the EPA and the entire Biden administration follow through on critical
protections for communities that have historically borne the brunt-of deadly pollution from power
plants and may continue to face power plant pollution. Our climate can’t wait. The EPA must act by early
2024 to finalize the strongest possible standards to cut climate pollution from power plants
128

American
eM Sustainable
‘I Business
“SE” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My names drkrpelletier@aol.com Pelletier and I’m from San Francisco, CA. | am writing to express my,
and my organization, UCSF School of Medicine’s, strong support for the Biden administration’s proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically
important step forward, providing a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. Listen to scientists’ warnings about the
urgent need for climate action and the voices of those living near power plants most impacted by their
emissions, which are disproportionately low-income and communities of color. By providing several
different opportunities for compliance and multiple financial incentives, power plants will have what
they need to move forward with rapid emission reduction. | encourage the agency to move forward with
this proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
129

American

| Sustainable
' Business
Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Ri Rule EPA-HQ-OAR-2023-0072

My name is s Christopher Overholt and I’m from Brier, WA. | am writing to express my, and my
organization, Namu Baru Inc.’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants, As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
130

2S American
if = Sustainable
MJ usiness
Se Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Jill Matteson and I’m from Los Angeles, CA. | am writing to express my, and my organization,
Gravender Farms’s, strong support for the Biden administration's proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired. power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long, EPA’s proposal is a critically important step
forward, providing a clear end point for-where the industry needs to get to as well as pathways to .
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
131

ais American
YVAN Sustainable

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072 ~

My name is Emma Jacobs and I’m from Orlando, FL. | am writing to express my, and my organization,
Legacy Vacation Resorts’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This. proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
132

American
RN Sustainable
ey Business

Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Cheryl Elkins and I’m from San Diego, CA. | am writing to express my, and my organization,
Chery! Elkins Jewelry’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
133

AS

eS. American
2) Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Dave Smith and (’m from Columbia, SC. | am writing to express my, and my organization,
Senior Express USA’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. EPA’s proposal is a-critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
134

Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Jim Loveland and I’m from Saint Petersburg, FL. 1 am writing to express my strong support
for the Biden administration’s proposed standards to cut climate pollution from coal- and natural gas-
fired power plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon
pollution, using the air our communities and businesses are dependent upon as a dumping ground for
far too long. EPA’s proposalis a critically important step forward, providing a clear end point for where -
the industry needs to get to as well as pathways to modernize how we produce power in this country.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. By providing several different opportunities for compliance and multiple financial
incentives, power plants will have what they need to move forward with rapid emission reduction. |
encourage the agency to move forward with this proposal and work to achieve greater cuts to pollution
from more sources on the fastest possible timelines. This proposal would avoid 1,300 premature
deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000:school absences, and
66,000 lost work days providing up to $85 billion in net climate and public health benefits. It is critical
that in tandem with this standard, the EPA and the entire Biden administration follow through on critical
protections for communities that have historically borne the brunt of deadly pollution from power
plants and may continue to face power plant pollution. Our climate can’t wait. The EPA must act by early
2024 to finalize the strongest possible standards to cut climate pollution from power plants
135

American
i Sustainable

ay Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Alan Peterson and I’m from Quarryville, PA. | am writing to express my, and my
organization, PSR’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this :
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
136

BS. American
7! Business

Ea” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed

EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Karen Berger and I’m from Montrose, CA. | am writing to express my strong support for the
Biden administration’s proposed standards to cut climate pollution from coal- and natural gas-fired
power plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon
pollution, using the air our communities and businesses are dependent upon as a dumping ground for
far too long. EPA’s proposal is a critically important step forward, providing a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. By providing several different opportunities for compliance and multiple financial
incentives, power plants will have what they need to move forward with rapid emission reduction. |
encourage the agency to move forward with this proposal and work to achieve greater cuts to pollution
from more sources on the fastest possible timelines. This proposal would avoid 1,300 premature
deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000: school absences, and
66,000 lost work days providing up to $85 billion in net climate and public health benefits. It is critical
that in tandem with this standard, the EPA and the entire Biden administration follow through on critical
protections for communities that have historically borne the brunt of deadly pollution from power
plants and may continue to face power plant pollution. Our climate can’t wait. The EPA must act by early
2024 to finalize the strongest possible standards to cut climate pollution from power plants
137

#25 American

SN Sustainable
' Business
“WE” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Christopher Horner and I’m from Santa Barbara, CA. | am writing to express my strong
support for the Biden administration’s proposed standards to cut climate pollution from coal- and
natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the largest sources
of carbon pollution, using the air our communities and businesses are dependent upon as a dumping
ground for far too long. EPA’s proposal is a critically important step forward, providing a clear end point
for where the industry needs to get to as well as pathways to modernize how we produce power in this
country. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. By providing several different opportunities for compliance and multiple
financial incentives, power plants will have what they need to move forward with rapid emission
reduction. | encourage the agency to move forward with this proposal and work to achieve greater cuts
to pollution from more sources on the fastest possible timelines. This proposal would avoid 1,300
premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school
absences, and 66,000 lost work days providing up to $85 billion in net climate and public health benefits.
It is critical that in tandem with this standard, the EPA and the entire Biden administration follow
through on critical protections for communities that have historically borne the brunt of deadly
pollution from power plants and may continue to face power plant pollution. Our climate can’t wait. The
EPA must act by early 2024 to finalize the strongest possible standards to cut climate pollution from
power plants
138

DS. American
MN, Sustainable
727! Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean ©
Energy Rule EPA-HOQ-OAR-2023-0072

My name is Ileana vasquez and I’m from Seattle, WA. | am writing to express my, and my organization,
LolitaMoon Productions’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
139

ES. American
Yay Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Saab Lofton and I’m from Seattle, WA. | am writing to express my strong support for the
Biden administration’s proposed standards to cut climate pollution from coal- and natural gas-fired
power plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon
pollution, using the air our communities and businesses are dependent upon as a dumping ground for
far too long. EPA’s proposal is a critically important step forward, providing a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. By providing several different opportunities for compliance and multiple financial
incentives, power plants will have what they need to move forward with rapid emission reduction. |
encourage the agency to move forward with this proposal and work to achieve greater cuts to pollution
from more sources on the fastest possible timelines. This proposal would avoid 1,300 premature
deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and
66,000 lost work days providing up to $85 billion in net climate and public health benefits. It is critical
that in tandem with this standard, the EPA and the entire Biden administration follow through on critical
protections for communities that have historically borne the brunt of deadly pollution from power
plants and may continue to face power plant pollution. Our climate can’t wait. The EPA must act by early
2024 to finalize the strongest possible standards to cut climate pollution from power plants
140

Je American
SN Sustainable

N V2) Business

“Si” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HOQ-OAR-2023-0072

My name is Michael Londo and I’m from West Chicago, IL. | am writing to express my, and my
organization, Just in Time Direction’s, strong support for the Biden administration’s proposed standards
to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired
power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically
important step forward, providing a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. Listen to scientists’ warnings about the
urgent need for climate action and the voices of those living near power plants most impacted by their
emissions, which are disproportionately low-income and communities of color. By providing several
different opportunities for compliance and multiple financial incentives, power plants will have what
they need to move forward with rapid emission reduction. | encourage the agency to move forward with
this proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
141

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean *
Energy Rule EPA-HQ-OAR-2023-0072

My name is Jarrett Cloud and I’m from Stanhope, NJ. | am writing to express my strong support for the
Biden administration’s proposed standards to cut climate pollution from coal- and natural gas-fired
power plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon
pollution, using the air our communities and businesses are dependent upon as a dumping ground for
far too long. EPA’s proposal is a critically important step forward, providing a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. By providing several different opportunities for compliance and multiple financial
incentives, power plants will have what they need to move forward with rapid emission reduction. |
encourage the agency to move forward with this proposal and work to achieve greater cuts to pollution
from more sources on the fastest possible timelines, This proposal would avoid 1,300 premature
deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and
66,000 lost work days providing up to $85 billion in net climate and public health benefits. It is critical
that in tandem with this standard, the EPA and the entire Biden administration follow through on critical
protections for communities that have historically borne the brunt of deadly pollution from power
plants and may continue to face power plant pollution. Our climate can’t wait. The EPA must act by early
2024 to finalize the strongest possible standards to cut climate pollution from power plants
142

—

SS American
SM Sustainable
“Sle” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Kaneisha Lewis and I’m from Fort Worth, TX. | am writing to express my, and my
organization, Cantey Hanger, LLP’s, strong support for the Biden administration’s proposed standards to
cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as. a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution,
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
143

American

oN
SA Sustainable

ia
Vea Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072 .

My name is Alysha Schultz and I’m from West Linn, OR. | am writing to express my, and my organization,
Intuitive Digital’s, strong support for the Biden administration's proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources.on the fastest possible
timelines, This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the .
entire Biden administration follow through on critical protections for communities that have historically
.borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
144

oy Sustainable
Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Heather Mason and I’m from Marina del Rey, CA. | am writing to express my, and my
organization, Caspian Agency’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their. emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
145

American
KIN Sustainable
\ Nay Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Paul Wythes and I’m from San Francisco, CA. | am writing to express my, and my
organization, Oakdell Capital’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt-of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
146

oN American
NIN Sustainable
“Siar Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HOQ-OAR-2023-0072

My name is Cheryl Spector and I’m from Denver, CO. | am writing to express my, and my organization,
Spector and Associates’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. EPA’s proposal is a critically important step
forward, providing a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. It is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
147

American
RN Sustainable

A ay Business

(2 Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HOQ-OAR-2023-0072

My name is Gregory Garnant and I’m from New York, NY. | am writing to express my, and my
organization, Garnant Computer Services’s, strong support for the Biden administration’s proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. EPA’s proposal isa critically
important step forward, providing a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. Listen to scientists’ warnings about the
urgent need for climate action and the voices of those living near power plants most impacted by their
emissions, which are disproportionately low-income and communities of color. By providing several
different opportunities for compliance and multiple financial incentives, power plants will have what
they need to move forward with rapid emission reduction. | encourage the agency to move forward with
this proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. This proposal would avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. it is critical that in tandem with this standard, the EPA and the
entire Biden administration follow through on critical protections for communities that have historically
borne the brunt of deadly pollution from power plants and may continue to face power plant pollution.
Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut
climate pollution from power plants
148

SIN Sustainable
“eee” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Maureen Vagnini and I’m from Windsor, CT. | am writing to express my strong support for
the Biden administration’s proposed standards to cut climate pollution from coal- and natural gas-fired
power plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon
pollution, using the air our communities and businesses are dependent upon as a dumping ground for
far too long, EPA’s proposal is a critically important step forward, providing:a clear end point for where
the industry needs to get to as weil as pathways to modernize how we produce power in this country.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. By providing several different opportunities for compliance and multiple financial
incentives, power plants will have what they need to move forward with rapid emission reduction. |
encourage the agency to move forward with this proposal and work to achieve greater cuts to pollution
from more sources on the fastest possible timelines. This proposal would avoid 1,300 premature
deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and
66,000 lost work days providing up to $85 billion in net climate and public health benefits. It is critical
that in tandem with this standard, the EPA and the entire Biden administration follow through on critical
protections for communities that have historically borne the brunt of deadly pollution from power
plants and may. continue to face power plant pollution. Our climate can’t wait. The EPA must act by early
2024 to finalize the strongest possible standards to cut climate pollution from power plants
149

American
Sh, Sustainable

Wi : ay Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Anna Sampson and I’m from Gainesville, FL. | am writing to express my, and my
organization, We Are Neutral's, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,'
150

American
/ KN Sustainable
AY ay Business

Sr Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HO-OAR-2023-0072

My name is Janet Morgan and I’m from Boulder, CO. | am sending this email to express my, and my
organization, Sequent Management Inc.’s, strong support for the Biden administration’s proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. Fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits, PLEASE, listen to scientists’ warnings about the urgent need for climate action and the voices
of those living near power plants most impacted by their emissions, which are disproportionately low-
income and communities of color. This critically important step forward provides a clear end point for
where the industry needs to get to as well as pathways to modernize how we produce power in this.
country. By providing several different opportunities for compliance and multiple financial incentives,
power plants will have what they need to move forward with rapid emission reduction. | encourage the
agency to move forward with this proposal and work to achieve greater cuts to pollution from more
sources on the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to
finalize the strongest possible standards to cut climate pollution from power plants. Thank you, Janet
M. Morgan’
151

American
SN Sustainable
' Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Gina Olson and I’m from Aspen, Colorado | am writing to express my, and my organization,
Livable Planet's, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,’
152

3] Sustainable

=

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Susan Richman and I’m from Durham, New Hampshire. | am writing to express the my
strong support, and the support of my organization, New Hampshire Network for Environment, Energy
and Climate, for the Biden administration’s proposed standards to cut climate pollution from coal- and
natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the largest sources
of carbon pollution, using the air our communities and businesses are dependent upon as a dumping
ground for far too long. The federal government must take a.strong leadership role in fighting climate
pollution. | live.in a state that is reluctant to acknowledge human-caused climate change, and resists
setting goals or standards, or promoting helpful initiatives such as energy efficiency or net metering or
EV charging. We rely on the federal government to take the brave moves. If enacted the EPA’s proposal
will allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma
attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and
public health benefits. Listen to scientists’ warnings about the urgent need for climate action.and the
voices of those living near power plants most impacted by their emissions, which are disproportionately
low-income and communities of color. This critically important step forward provides a clear end point
for where the industry needs to get to as well as pathways to modernize how we produce power in this
country, By providing several different opportunities for compliance and multiple financial incentives,
power plants will have what they need to move forward with rapid emission reduction. | encourage the
agency to move forward with this proposal and work to achieve greater cuts to pollution from more
sources on the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to
finalize the strongest possible standards to cut climate pollution from power plants. Thank you,’
153

KIN Sustainable

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

lam writing to express my strong support for the Biden administration’s proposed standards to cut
climate pollution from coal and natural gas-fired power plants; begin the conversion to completely
renewable energy generation. In the 1960s the LBJ administration received study information warning
of the climate change potential from hydrocarbon based fuel burning. Oil and gas company scientists
echoed those warning from, at least, the 1970s... So, what did they do? The Carter administration put
solar panels on the White House, then the following, Reagan, administration removed them. In the late
1970s Mobil Oil bought Tyco Laboratories, a company that produced solar panels, and did little, to
nothing, with the company... shut it down 19 years later. This the shortest list of things done to stall the
conversion to renewables, by industries that could have afforded to be on the leading edge of said
renewable conversion (see also: Merchants of Doubt by Naomi Oreskes and Erik M. Conway). As we
know, fossil fuel-fired power plants are one of the largest sources of carbon pollution, using the air our
communities and businesses are dependent upon as a dumping ground for far too long. If enacted the
EPA’s proposal will allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. Listen to scientists’ warnings about the urgent need for climate
action and the voices of those living near power plants most impacted by their emissions, which are
disproportionately low-income and-communities of color. This critically important step forward
provides a clear end point for where the industry needs to get to as well as pathways to modernize how
we produce power in this country. By providing several different opportunities for compliance and
multiple financial incentives, power plants will have what they need to move forward with rapid
emission reduction. | encourage the agency to move forward with this proposal and work to achieve
greater cuts to pollution from more sources on the fastest possible timelines. Inertia has ruled the day
so far and only significant pressure from government agencies, such as the EPA, can kick start the effort
to convert to renewable energy. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,’
154

io. American

r/ | SN Sustainable

SS” N Network

Docket Number: New Source Performance Standards for GHG Emissions from New aid Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is George Chmael Il and I’m from Annapolis, Maryland . | am writing to express my, and my
organization, Council Fire’s, strong support for the Biden administration’s proposed standards to cut.
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear'end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By. providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution fram more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,’
155

SA Sustainable
\' Business
Ba’ Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Diane Keefe and I’m from Norwalk.CT | strongly support the Biden administration’s
proposed standards to cut climate pollution from coal- and natural gas-fired power plants. As we know,
fossil fuel-fired power plants are one of the largest sources of carbon pollution, using the air our
communities and businesses are dependent upon as a dumping ground for far too long. If enacted the
EPA's proposal will allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. Listen to scientists’ warnings about the urgent need for climate
action and the voices of those living near power plants most impacted by their emissions, which are
disproportionately low-income and communities of color. This critically important step provides a clear
end point for where the industry needs to get to as well as pathways to modernize how we produce
power in this country. By providing several different opportunities for compliance and multiple financial
incentives, power plants will have what they need to move forward with rapid emission reduction. |
encourage the agency to move forward with this proposal and work to achieve greater cuts to pollution
from more sources on the fastest possible timelines. Our climate can’t wait. The EPA must act by early
2024 to finalize the strongest possible standards to cut climate pollution from power plants. Thank you,'
156

American

by Sustainable
usiness

“ee” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA~HO-OAR-2023-0072

My name is Carrie VanWinkle and I’m from Louisville, Kentucky. | am writing to express my strong
support for the Biden administration’s proposed standards to cut climate pollution from coal- and
natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the largest sources
of carbon pollution, using the air our communities and businesses are dependent upon as a dumping
ground for far too long. If enacted the EPA’s proposal will allow us to avoid 1,300 premature deaths,
800 hospital-and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and 66,000 lost
work days providing up to $85 billion in net climate and public health benefits. Listen to scientists’
warnings about the urgent need for climate action and the voices of those living near power plants most
impacted by their emissions, which are disproportionately low-income and communities of color. This
critically important step forward provides a clear end point for where the industry needs to get to as
well as pathways to modernize how we produce power in this country. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible
standards to cut climate pollution from power plants. Thank you, Carrie!
157

S25 American
NSO usiness

“ue” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs;.and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Theodora Skeadas and I’m from Cambridge, MA. | am writing to express my, and my
organization, Cambridge Local First’s, strong support for the Biden administration’s proposed standards
to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired
power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will
allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks,
38,000 school absences, and 66,000 lost work days providing up to.$85 billion in net climate and public
health benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of
those living near power plants most impacted by their emissions, which are disproportionately low-
income and communities of color. This critically important step forward provides a clear end point for
where the industry needs to get to as well as_ pathways to modernize how we produce power in this
country. By providing several different opportunities for compliance and multiple financial incentives,
power plants will have what they need to move forward with rapid emission reduction. | encourage the
agency to move forward with this proposal and work to achieve greater cuts to pollution from more
sources on the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to
finalize the strongest possible standards to cut climate pollution from power plants. Thank you,'
158

American

KN Sustainable

N ay Business

Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072 ;

My name is Mike Brown and I’m from Irvine, California. | am writing to express my, and my organization,
impact Grove's, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a.clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,'
159

Sy Sustainable
7 Business

Ba’ Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Aria McKenna and I’m from Saint Augustine, Florida. | am [writing] to express my, and my
‘organization, Global Cooling Productions’, strong support for the Biden administration’s proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will
allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks,
38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and public
health benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of
those living near power plants most impacted by their emissions, which are disproportionately low-
income and communities of color. Furthermore, as we move forward with solutions, we must protect
our ecosystems and our climate from unintended consequences as new technologies are adopted. The
dangers of mining and the warming potential of hydrogen pipelines must not be overlooked as we
create a plan for a viable path forward, Technologies exist to do this safely but extreme vetting is
required to do so. This critically important step forward provides a clear end point for where the
industry needs to get to as well as pathways to modernize how we produce power in this country. By
providing several different opportunities for compliance and-multiple financial incentives, power plants
will have what they need to move forward with rapid emission reduction. | encourage the agency to
move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,'
160

~ American
Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HO-OAR-2023-0072

My name is Katherine DiMatteo and i’m from Leyden, MA. | am writing to express my, and my
organization, Wolf & Associates’, strong support for the Biden administration’s proposed standards to
cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of-color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to. move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our.climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,’
161

au Business
NOY Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Heather Burns and I’m from Bethel, Connecticut. |am [writing] to express my, and my
organization, Connecticut Sustainable Business Council’s strong support for the Biden administration's
proposed standards to cut climate pollution from coal- and natural gas-fired power plants. As we know,
fossil fuel-fired power plants are one of the largest sources of carbon pollution, using the air our
communities and businesses are dependent upon as a dumping ground for far too long. If enacted the
EPA’s proposal will allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. Listen to scientists’ warnings about the urgent need for climate
action and the voices of those living near power plants most impacted by their emissions, which are
disproportionately low-income and communities of color. This critically important step forward
provides a clear end point for where the industry needs to get to as well as pathways to modernize how
we produce power in this country. By providing several different opportunities for compliance and
multiple financial incentives, power plants will have what they need to move forward with rapid
emission reduction, | encourage the agency to. move forward with this proposal and work to achieve
greater cuts to pollution from more sources on the fastest possible timelines. Our climate can’t wait.
The EPA must act by early 2024 to finalize the strongest possible standards to cut climate pollution from
power plants. Thank you,’ ;
162

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Julia Collins and I’m from California | am writing to express my, and my organization, Planet
FWD's, strong support for the Biden administration’s proposed standards to cut climate pollution from
coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to avoid 1,300
premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school
absences, and 66,000 lost work days providing up to $85 billion in net climate and public health benefits.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. This critically important step forward provides a clear end point for where the
industry needs to get to as well as pathways to modernize how we produce power in this country. By
providing several different opportunities for compliance and multiple financial incentives, power plants
will have what they need to move forward with rapid emission reduction. | encourage the agency to
move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,’
163

225% American
SIN Sustainable

AY ay Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Kimberlee and I’m from Greenbrae, California. | want to express my, and my company's,
strong support for the Biden administration’s proposed standards to cut climate pollution from coal- and
natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the largest sources
of carbon pollution, using the air our communities and businesses are dependent upon as a dumping
ground for far too long. If enacted the EPA’s proposal will allow us to avoid 1,300 premature deaths,
800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and 66,000 lost
work days providing up to $85 billion in net climate and public health benefits. Listen to scientists’
warnings about the urgent need for climate action and the voices of those living near power plants most
impacted by their emissions, which are disproportionately low-income and communities of color. This
critically important step forward provides a clear end point for where the industry needs to get to as
well as pathways to modernize-how we produce power in this country. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible
standards to cut climate pollution from power plants.! would like to add that there is opportunity for
impactful-climate mitigation and carbon reductions with a focus on the plastic industry - a major
contributor. Thank you,’
164

SIN Sustainable

say Business

| 14 Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Nancy Hirshberg and I’m from Wolfeboro, NH. | am writing to express my strong support for
the Biden administration’s proposed standards to cut climate pollution from coal- and natural gas-fired
power plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon
pollution, using the air our communities and businesses are dependent upon as a dumping ground for
far too long. If enacted the EPA’s proposal will allow us to avoid 1,300 premature deaths, 800 hospital
and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days
providing up to $85 billion in net climate and public health benefits. Listen to scientists’ warnings about
the urgent need for climate action and the voices of those living near power plants most impacted by
their emissions, which are disproportionately low-income and communities of color. This critically
important step forward provides a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible
standards to cut climate pollution from power plants. Thank you,’
165

Sy Sustainable
2 Business
“Wie” = Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is John-Imes and I’m from the Village of Shorewood Hills, Wisconsin. | am writing to express
my, and my organization, WEI’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses.
are dependent upon as a dumping ground for far too long. Wisconsin coal power plants consumed
almost 14 million tons of coal in 2020 resulting in over 33 million tons of carbon dioxide (CO2) emissions,
not to mention other criteria pollutants including 21 million tons of Nitrogen Oxide (NOx), 14 million
tons of Sulfur Dioxide (SO2), plus particulate emissions and other pollutants. Source www.eia.gov If
enacted the EPA’s proposal will allow us to avoid 1,300 premature deaths, 800 hospital and ER visits,
more than 300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to
$85 billion in net climate and public health benefits. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. This critically important step
forward provides a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. By providing several different opportunities for
compliance and multiple financial incentives, power plants will have what they need to move forward
with rapid emission reduction. | encourage the agency to move forward with this proposal and work to
achieve greater cuts to pollution from more sources on the fastest possible timelines. Our climate can’t
wait. The EPA must act by early 2024 to finalize the strongest possible standards to cut climate pollution
from power plants. Thank you, John Imes'
166

ay Sustainable
' Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name isTim Wheeler and I’m fromDurango, CO. | am writing to express my, and my organization,
Durango Compost Company’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too Jong. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,’
167

American
SM Sustainable
72 Business

Sz” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Carol Phelps and I’m from Middleton, Wisconsin. rm writing to express my support, and the
support of Wisconsin Creation Care Ambassadors {a multi-faith organization which works to care for the
Earth and stop climate change), for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution. They have used the air our communities and businesses
are dependent upon as a dumping ground for far too long. If enacted, the EPA’s proposal is expected to
allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks,
38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and public
health benefits. Please listen to scientists’ warnings about the urgent need for climate action, and the
voices of those who are living near power plants most impacted by their emissions, which are
disproportionately low-income families and communities of color. This critically important step forward
provides a pathway to modernize how we produce power in this country. By providing several different
opportunities for compliance, and multiple financial incentives, power plants will have what they need
to move forward with rapid emissions reduction, | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. Our climate can’t wait. The longer we wait, the more disasters happen, the more people -
suffer, the more lives are lost, the more communities and ecosystems are impacted. Changes happening
today cannot be reversed (no one has a way to refreeze Greenland or Antarctica). Feedback loops (like .
wildfires, melting permafrost, increased water vapor in the air) are.in full swing. If we reach certain
“tipping points" (such as major ocean currents changing - e.g. the Gulf Stream no longer carrying warm
water to Europe), heaven help us. The EPA must act by early 2024 to finalize the strongest possible
standards to cut climate pollution from power plants. Thank you,’
168

American

RN Sustaina ble

\ B
NEY Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Kermit Hovey and I’m from Middleton, WI. | am writing to express my, and my organization,
Faiths Connect for Climate Action’s, strong support for the Biden administration’s proposed standards to
cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. Making money while inflicting the costs of
pollution on the rest of us should never be tolerated. If enacted the EPA’s proposal will allow us to avoid
1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school
absences, and 66,000 lost work days providing up to $85 billion in net climate and public health benefits.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. This critically important step forward provides a clear end point for where the
industry needs to get to as well as pathways to modernize how we produce power in this country. By
providing several different opportunities for compliance and multiple financial incentives, power plants
will have what they need to move forward with rapid emission reduction. | encourage the agency to.
move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. In the absence of the even more comprehensive
Energy Innovation and Carbon Dividend Act, The EPA must act by early 2024 to finalize the strongest
possible standards to cut climate pollution from power plants. Thank you,'
169

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is David Kyler and !’m from Saint Simons Island, Georgia. | am submitting this statement to
express the strong support of our non-profit organization, Center for a Sustainable Coast, for the Biden
administration’s proposed standards to decisively reduce climate pollution from coal- and natural gas-
fired power plants. As we know, fossil fuel-fired power plants are among the largest sources of heat-
trapping carbon pollution, using the air our communities, ecosystems, and businesses are dependent
upon as a dumping ground for far too long. If enacted, the EPA’s proposal will enable prevention of at
least 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work-days, providing an estimated $85 billion in short-term climate
and public-health benefits, and immeasurably more over the long-term. We must honor scientists’
warnings about the urgent need for climate action and the voices of those living near power plants who
are most harmed by power-plant emissions. These emission victims are disproportionately from low-
income groups and communities of color. This critically important step forward provides a clear and
worthy target for industry, as well as pathways for modernizing power-production methods in the U.S.
By providing several different opportunities for compliance and multiple financial incentives, power-
plant owners will have what is required to move ahead with rapid emission reduction. | encourage the
EPA to expediently adopt and implement this well-justified proposal and to work to achieve even
greater pollution reductions from more sources as quickly as possible. We must not delay in taking this
critical action to protect Earth's endangered climate and life-support systems. The EPA must act by early
2024 to finalize the strongest possible standards to minimize climate pollution from power plants. We
are depending on your commitment to serving the public interest. :
170

Jes. American

r/ | iN Sustainable
2) Business

“Se” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Adam Hamilton and I’m from Peterborough, NH. | am writing to express my, and my
organization, Clean Simple Foods, Inc’s, strong support for the Biden administration’s proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will
allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks,
38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and public
health benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of
those living near power plants most impacted by their emissions, which are disproportionately low-
income and communities of color. This critically important step forward provides a clear end point for
where the industry needs to get to as well as pathways to modernize how we produce power in this
country. By providing several different opportunities for compliance and multiple financial incentives,
power plants will have what they need to move forward with rapid emission reduction. | encourage the
agency to move forward with this proposal and work to achieve greater cuts to pollution from more
sources on the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to
finalize the strongest possible standards to cut climate pollution from power plants. Thank you,’
171

oN American
4 Sustainable

ZZ) Business
oy Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is James Elder and I’m from Manchester, MA. | am writing to express my, and my organization,
the Campaign for Environmental Literacy’s, strong support for the Biden administration’s proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. if enacted the EPA’s proposal will
allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks,
38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and public
health benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of
those living near power plants most impacted by their emissions, which are disproportionately low-
income and communities of color. This critically important step forward provides a clear end point for
where the industry needs to get to as well as pathways to modernize how we produce power in this
country. By providing several different opportunities for compliance and multiple financial incentives,
power plants will have what they need to move forward with rapid emission reduction. | encourage the
agency to move forward with this proposal and work to achieve greater cuts to pollution from more
sources on the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to
finalize the strongest possible standards to cut climate pollution from power plants. Thank you,’
172

American
2’ Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Jenny Davis and I’m writing to express my, and my Denver-based small business’, strong
support for the Biden administration’s proposed standards to cut climate pollution from coal- and
natural gas-fired power plants. As we know, fossil fuelfired power plants are one of the largest sources
of carbon pollution, using the air our communities and businesses are dependent upon as a dumping
ground for far too long.-tf enacted the EPA’s proposal will allow us to avoid 1,300 premature deaths,
800 hospital arid ER visits, more than 300,000 asthma attacks, 38,000 school absences, and 66,000 lost
work days providing up to $85 billion in net climate and public health benefits. Listen to scientists’
warnings about the urgent need for climate action and the voices of those living near power plants most
impacted by their emissions, which are disproportionately low-income and communities of color. This
critically important step forward provides a clear end point for where the industry needs to get to as
well as pathways to modernize how we produce power in this country. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible
standards to cut climate pollution from power plants. Thank you,’
173

American
I Sustainable
7’ Business

? Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordabie Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is chris Laszlo and I’m from Great Falls, Virginia. | am writing to express my, and my
organization, Sustainable Balue Partners’ strong support for the Biden administration's. proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will
allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks,
38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and public
health benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of
those living near power plants most impacted by their emissions, which are disproportionately low-
income and communities of color. This critically important step forward provides a clear end point for
where the industry needs to get to as well as pathways to modernize how we produce power in this
country. By providing several different opportunities for compliance and multiple financial incentives,
power plants will have what they need to move forward with rapid emission reduction. | encourage the
agency to move forward with this proposal and work to achieve greater cuts to pollution from more
sources on the fastest possible timelines. Our climate can‘t wait. The EPA must act by early 2024 to
finalize the strongest possible standards to cut climate pollution from power plants. Thank you,'
174

SN American

ay Sustainable
Na) Business
“Se” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Kim Craven and I’m from Madison, CT. | want to express my, and my organization, CSG
Communications Inc.; strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. We need strong and clear leadership to address
the effects of climate change as evidenced this summer across the globe. We can no longer afford to
wait for everyone to get on board. The EPA needs to lead to finalize the strongest possible standards to
cut climate pollution from power plants. Thank you for the work that you do on our behalf.’
175

American
i N Sustainable

oa” ~ Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Les Blevins and I’m from Lawrence Kansas. | am writing to express my, and my organization,
Advanced Alternative Energy’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid excessive hot weather, numerous flooding events, 1,300 premature deaths, 800 hospital and ER
visits, more than 300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing
up to $285 billion dollars in net climate and public health benefits. Please listen to scientists’ warnings
about the urgent need for climate action and the voices of those living in the United States along with
thousands of central power plants that add CO2 to the atmosphere and who are being impacted by their
emissions. This critically important step forward provides a clear end point for where the industry needs
to get to as well as pathways to modernize how we produce power in this country. By providing several
different opportunities for compliance and multiple financial incentives, power plants will have what
they need to move forward with rapid greenhouse emission reductions. I'm writing to encourage the
agency to move forward with this proposal and work to achieve greater cuts to pollution from more
sources on the fastest possible timelines and with the least costly measures. Our climate can’t wait. The
EPA must act to finalize the strongest possible standards to cut climate pollution from power plants all
across our land and set an example for China and India and other countries. Thank you, Les Blevins of
Advanced Alternative Energy Co. CO2 Emission cuts alone could make the earth much hotter while
adding aerosols could cool the earth scientists say. BY SAUL ELBEIN & LES BLEVINS Scientists have
recently uncovered a potentially lethal paradox at the heart of efforts to slow human-caused climate
change. A series of new studies suggest a stark truth. On the one hand, cutting fossil fuel pollution is
necessary for avoiding more severe destruction over the long term. But such cuts will make the earth
much hotter in the short term. One recent study cast the well-known declines in air pollution during the
COVID-19 pandemic in a darker light. These cuts remain one of the only examples of successful cuts to
climate-warming pollution, but the new study found that those pandemic-era cuts in air pollution led to
a rise in global temperatures. The findings, published on Wednesday in the journal NPJ Climate and
Atmospheric Science, unveil a stark paradox at the heart of human-caused climate change. It suggests
that while cutting fossil fuel pollution is necessary for avoiding severe destruction over the long term —
such cuts alone will make things noticeably worse in the short term. The pandemic-era economic
slowdown led to “a large-scale geophysical experiment,” study leader Orjan Gustafsson of Stockholm
University said in a statement. That’s because the shuttered factories and power plants led to a
corresponding crash in emissions. Even so, not ail emissions fell in the same way. From a research
station in the Maldives, an island archipelago off the coast of India, Gustafsson’s team detected that
when pollution from smokestacks fell, so did concentrations of aerosols — tiny floating particles that
hang in the atmosphere. That fall was an unmistakable boon to public health. According to Our World in
176

Data, these contaminants — like tiny floating particles of soot or sulfates — cause millions of global
deaths per year. But for all the damage they do to human lungs, aerosols also help shade the earth by
scattering light particles from the sun that would otherwise warm the planet. After the cuts, the study
found that light reaching the surface increased by 7 percent. “While the sky became bluer and the air
cleaner, climate warming increased when these cooling air particles were removed,” Gustafsson said.
While aerosol concentrations fell as the smokestacks shut down, other gases remained stubbornly high.
In particular, levels of the most potent climate-warming gases — like carbon dioxide — barely changed.
Carbon dioxide and other greenhouse gases warm the planet by trapping heat. The combination of more
heat hitting the same amount of carbon dioxide meant a straightforward rise in temperatures. The
sudden rise in temperatures led by the pandemic reduction is a stark example of a more general
problem — one that has long haunted the drive to cut pollution. A draft study led by Columbia
University climate scientist James Hansen suggests that the recent-rise in temperatures doesn’t come
from greenhouse gases at all, but from the reduction in sulfate aerosols since the early-2000s.'
177

2 American

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Janine Firpo and I’m from Oakland, California. | am writing to express my, and my
organization, invest for Better's, strong support for the Biden administration’s proposed standards to
cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,’
178

eS. American

Sy Sustainable

27) Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Keeley and i’m from Boulder, Colorado. | am writing to express my, and my organization,
The Alliance for Collective Action’s, strong support for the Biden administration’s proposed standards to
cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital.and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward withrapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants, Thank you, Keeley Stokes'
179

oy Sustainable
Business
“Se” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Réconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Stacia Betley and I’m from New Haven, VT. | am writing to express my, and my organization,
MegaFood’s, strong support for the Biden administration’s proposed standards to cut climate pollution
from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. if enacted the EPA’s proposal will allow us to avoid 1,300
premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school
absences, and 66,000 lost work days providing up to $85 billion in net climate and public health benefits.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. This critically important step forward provides a clear end point for where the
industry needs to get to as well as pathways to modernize how we produce power in this country. By
providing several different opportunities for compliance and multiple financial incentives, power plants
will have what they need to move forward with rapid emission reduction. | encourage the agency to
move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by-early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,’
180

American
M7, Sustainable
NV) Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Tim: Redmond and I’m from Dexter, Mi. | am [writing] to express my, and my organization,
Skinny Farm’s, strong support for the Biden administration’s proposed standards to cut climate pollution
from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as. a dumping ground for far too long. If enacted the EPA’s proposal will allow us to avoid 1,300
premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school .
absences, and 66,000 lost work days providing up to $85 billion in net climate and public health benefits.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. This critically important step forward provides a clear end point for where the
industry needs to get to.as well as pathways to modernize how we produce power in this country. By
providing several different opportunities for compliance and multiple financial incentives, power plants
will have what they need to move forward with rapid emission reduction. | encourage the agency to
move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants: Thank you,
181

ISN Sustainable

NY Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is William Nash and I’m from Long Beach, California. | am writing to express my, strong
support for the Biden administration’s proposed standards to cut climate pollution from coal- and
natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the largest sources
of carbon pollution, using the air our communities and businesses are dependent upon as a dumping
ground for far too long. If enacted the EPA’s proposal will allow us to avoid 1,300 premature deaths,
800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and 66,000 lost
work days providing up to $85 billion in net climate and public health benefits. Listen to scientists’
warnings about the urgent need for climate action and the voices of those living near power plants most
impacted by their emissions, which are disproportionately low-income and communities of color. This
critically important step forward provides a clear end point for where the industry needs to get to as
well as pathways to modernize how we produce power in this country. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to. move forward with this
proposal and work to achieve greater cuts to pollution from more sources.on the fastest possible
timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible
standards to cut climate pollution from power plants. Thank you,'
182

£2 American
Sustainable
VAY) Business

NS” Network

\

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Mark Kleinschmit and I’m from Park Ridge, Illinois. | am writing to express my, and my
organization, Other Half Processing's, strong support for the Biden administration’s proposed standards
to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired
power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will
allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks,
38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and public
health benefits, Listen to scientists’ warnings about the urgent need for climate action and the voices of
those living near power plants most impacted by their emissions, which are disproportionately low-
income and communities of color. This critically important step forward provides a clear end point for
where the industry needs to get to as well as pathways to modernize how we produce power in this
country. By providing several different opportunities for compliance and multiple financial incentives,
power plants will have what they need to move forward with rapid emission reduction. | encourage the
agency to move forward with this proposal and work to achieve greater cuts to pollution from more
sources on the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to
finalize the strongest possible standards to cut climate pollution from power plants. Thank you,’
183

i= American
Sy Sustainable

22 Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Lorna Lyons and I’m from Portland OR. | am emailing to express my, and my organization
ASBN's strong support for the Biden administration’s proposed standards to cut climate pollution from
coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and. businesses are dependent upon
as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to avoid 1,300
premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school
absences, and 66,000 lost work days providing up to $85 billion in net climate and public health benefits.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. This critically important step forward provides a clear end point for where the
industry needs to get to as well as pathways to modernize how we produce power in this country. By
providing several different opportunities for compliance and multiple financial incentives, power plants
will have what they need to move forward with rapid emission reduction. | encourage the agency to
move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,’
184

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA~-HQ-OAR-2023-0072

My name is Patrick Thompson and I’m from Atlanta, GA. | am writing to express my, and my
organization, TerraScale's, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities-and businesses
are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300-premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,’
185

Z American
VS , Sustainable

i
S24 Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Linda Brent and (’m from Chapel Hill, NC. | am writing to express my, and my organization,
Blue Toby’s, strong support for the Biden administration’s proposed standards to cut climate pollution
from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to avoid 1,300
premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school
absences, and 66,000 lost work days providing up to $85 billion in net climate and public health benefits.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. This critically important step forward provides a clear end point for where the
industry needs to get to as weil as pathways to modernize how we produce power in this country. By
providing several different opportunities for compliance and multiple financial incentives, power plants
will have what they need to move forward with rapid emission reduction. | encourage the agency to
move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,’
186

AN Sustainable
: ay! Business

al Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Denise and I’m from Spokane WA and | am writing to express my, and my organization,
Ganesh Himal Trading’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon asa dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power.
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,"
187

SS. American
a Sustainable

NK Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Mark Canright. I'm a New Jersey farmer in Asbury NJ. | am writing to express my, and my
business's, strong support for the Biden administration’s proposed standards to cut climate pollution
from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the .
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. It's time to stop burning fossil fuels immediately if we want to
survive as a human race. If enacted the EPA’s proposal will allow us to avoid 1,300 premature deaths,
800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and 66,000 lost
work days providing up to $85 billion in net climate and public health benefits. Listen to scientists’
warnings about the urgent need for climate action and the voices of those living near power plants most
impacted by their emissions, which are disproportionately low-income and communities of color. This
critically important step forward provides a clear end point for where the industry needs to get to as
well as pathways to modernize how we produce power in this country. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible
standards to cut climate pollution from power plants. Thank you,'
188

\ American
27’ Business
“SEZ” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Anna Marie Lyles and I’m from Princeton, NJ. | am [writing] to express my, and my
organization, [org name]’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial! incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait and this will improve public health too. The EPA
must act by early 2024 to finalize the strongest possible standards to cut climate pollution from power
plants. Thank you,’
189

SN American
SIN Sustainable
| Network

4

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HOQ-OAR-2023-0072

My name is Joe Magid and I’m from Wynnewood, PA. | am writing to express my, and my organization,
Gryphon Solution, LLC’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net.climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,‘
190

=\ American
KOT Sustainable
Business
SE” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Lori and I’m from [Dallas, Tx. | am writing to express my, and my organization,, Conscious
Leaders, Inc, strong support for the Biden administration’s proposed standards to cut climate pollution
from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to avoid 1,300
premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school ;
absences, and 66,000 lost work days providing up to $85 billion in net climate and public health benefits.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. This critically important step forward provides a clear end point for where the
industry needs to get to as well as pathways to modernize how we produce power in this country. By
providing several different opportunities for compliance and multiple financial incentives, power plants
will have what they need to move forward with rapid emission reduction. | encourage the agency to
move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you, Lori Darley'
191

NN American
SIN Sustainable

ZV Business
ee Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Laurie Allan and I’m from Upstate New York new Rochesterwhere the air we breathe has
been unhealthy for several days over a period of about 3-4 weeks.. | am writing to express my, and my
organization, Laurie Allan & Associates, LLCs, strong support for the Biden administration’s proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will
allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks,
38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and public
health benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of
those living near power plants most impacted by their emissions, which are disproportionately low-
income and communities of color. This critically important step forward provides a clear end point for
where the industry needs to get to as well as pathways to modernize how we produce power in this
country. By providing several different opportunities for compliance and multiple financial incentives,
power plants will have what they need to move forward with rapid emission reduction, | encourage the
agency to move forward with this proposal and work to achieve greater cuts to pollution from more
sources on the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to
finalize the strongest possible standards to cut climate pollution from power plants. Our world is quite
literally on fire as | write this and it is idiocy to think that it will not get worse, food supply will be
affected, and future generations will never forgive out lack of courage to act and remedy global climate
change. Thank you,’
192

SN Sustainable
ZV’ Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Scott Hill and I’m from Springville, NY. | am writing to express my, and my organization, J.
Kraft Microscopy Services’, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen 'to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. | suffer from asthma, so this proposal could literally be a life-saver for me.
This critically important step forward provides a clear end point for where the industry needs to get to
as well as pathways to modernize how we produce power in this country. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible
standards to cut climate pollution from power plants. Thank you,'
193

2 Business

“Sle” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is David J. FERRAN and I’m from SAN Diego Ca. | am eniail you to to express my, and my
organization, Torrey Project]’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,' ;
194

~ American
9), Sustainable
Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072 :

My name is Dr.Robert Vinetz, M.D. a pediatrician in Los Angeles, California. I've seen hundreds and
hundreds of children with asthma...asthma triggered by and made much worse by the polluted, toxic air
we all breathe. The ultra/fine particles in that air get into our blood, bodies and brains...even into those
of the unborn. Research shows this causes harm, including (but not limited to) lung and developmental
defects. | urge the EPA and the Biden Administration to enact the strongest possible standards to
protect children and everyone on earth from the toxic impact of fossil fuels on our climate and our lives.
Please, please do not cave in to the fossil fuel industry that for decades knew they were unleashing
untold harm on life on our planet, but chose making money over protecting life. The EPA’s proposed
carbon pollution standards plan provides a clear end-point for where the industry needs to get to, as
well as pathways to modernize how we produce power in this country and cut climate pollution from
existing coal, gas, and new gas power plants. If enacted the EPA’s proposal will allow us to avoid 1,300
premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school
absences, and 66,000 lost work days.providing up to $85 billion in net climate and public health benefits.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. This critically important step forward provides a clear end point for where the
industry needs to get to as well as pathways to modernize how we produce power in this country. By
providing several different opportunities for compliance and multiple financial incentives, power plants
will have what they need to move forward with rapid emission reduction. | encourage the agency to
move forward with this, proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines, Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,'
195

ES. American

ay Sustainable
usiness
AS | ay Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA- HOQ-OAR-2023-0072

My name is Sally Malanga and I’m from West Orange, New Jersey. | am writing to express my, and my
organization, New Earth, LLC’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources.on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,‘
196

NM Sustainable
NSA Business

Docket Nurmber: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Harry Doull and I’m from Kingston, NY. }am writing to express my, and my organization,
Keap Candles’, strong support for the Biden administration’s proposed standards to cut climate pollution
from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to avoid 1,300
premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school
absences, and 66,000 lost work days providing up to $85 billion in net climate and public health benefits.
Listen to scientists’ warnings about the urgent need for climate action and-the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color.. This critically important step forward provides a clear end point for where the
industry needs to get to as well as pathways to modernize how we produce power in this country. By
providing several different opportunities for compliance and multiple financial incentives, power plants
will have what they need to move forward with rapid emission reduction. | encourage the agency to
move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,'
197

<N American
SIN Sustainable

77) Business
cy Network

Docket Number: New Source Performance Standards for GHG Emissions from New atid Reconstructed
EGUs; Emission Guidelines for GHG Emissions from m Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Brad Brooks and I’m from East Hampton NY. | am writing to express my strong support for
the Biden administration’s proposed standards to cut climate pollution from coal- and natural gas-fired
power plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon
pollution, using the air our communities and businesses are dependent upon as a dumping ground for
far too long. This critically important step forward provides a clear end point for where the industry
needs to get to as well as pathways to modernize how we produce power in this country. By providing
several different opportunities for compliance and multiple financial incentives, power plants will have
what they need to move forward with rapid emission reduction. | encourage the agency to move
forward with this proposal and work to achieve greater cuts to pollution from more sources on the
fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. It also finally has to do a better
analysis of methane and its large impact on Climate Change. The EPA is making a mistake by continuing
to use a 100-year period to compare its impact versus Co2 - the correct factor would be 84x as powerful
than Co2 than the current 28X | believe your agency currently uses. Moreover, new studies are needed
that would show that methane is leaking throughout the infrastructure system at a far greater rate than
just the 2% assumed by your agency. More realistically the rate is likely 2-3x that, which would make
methane a bigger problem than C02 over the next 20-year time period. Methane (natural gas) can also
be easily used in our current utility system, so much better regulations and penalties need to finally be
implemented to limit the escape of this powerful ghg emission. Thank you, Brad Brooks CFA'
198

BS. American
MN Sustainable
“Sz” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Susan Webb and I’m from Madison, Wisconsin . | am [writing] to express my strong support
for the Biden administration’s proposed standards to cut climate pollution from coal- and natural gas-
fired power plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon
pollution, using the air our communities and businesses are dependent upon as a dumping ground for
far too long. If enacted the EPA’s proposal will allow us to avoid 1,300 premature deaths, 800 hospital
and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days
providing up to $85 billion in net climate and public health benefits. Listen to scientists’ warnings about
the urgent need for climate action and the voices of those living near power plants most impacted by
their emissions, which are disproportionately low-income and communities of color. This critically
important step forward provides a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources-on the fastest possible
timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible
standards to cut climate pollution from power plants. Thank you,’
199

—

25 American
SN Sustainable

cy Network

a

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Brittany Phelps and I’m from Waunakee, WI. | strongly support the Biden administration’s
proposed standards to cut climate pollution from fossil fuel power plants because they are are one of
the largest sources of carbon pollution. If enacted, the EPA’s proposal will allow us to avoid 1,300
premature deaths, 800.hospital and ER visits, more than 300,000 asthma attacks, 38,000 school
absences, and 66,000 lost work days providing up to $85 billion in net climate and public health benefits.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. This critically important step forward provides a clear end point for where the
industry needs to get to as well as pathways to modernize how we produce power in this country. By
providing several different opportunities for compliance and multiple financial incentives, power plants
will have what they need to move forward with rapid emission reduction. | encourage the agency to
move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants, Thank you,’
200

SN Sustainable

‘ee Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Dann Carnes and I’m from Chapel Hill, NC. | am writing to express my, and my organization,
Fireplace Editions’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,’
201

eS. American

JAS Sustainable

ee Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HOQ-OAR-2023-0072

My name is Jennifer Nichols and I’m from Lenni, PA. | am writing to express my, and my organization,
GreenWeaver Landscapes’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,'
202

\ American
RN Sustainable

WEA Business
Yee Network

Docket Number: New Source Performance Standards for GHG Emissions from New. and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HOQ-OAR-2023-0072

My name is Dana Davis and I’m from NYC, NY. | am [writing] to express my, and my organization,Mara
Hoffman's, strong support for the Biden administration’s proposed standards to cut climate pollution
from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to avoid 1,300
premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school
absences, and 66,000 lost work days providing up to $85 billion in net climate and public health benefits.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. This critically important step forward provides a clear end point for where the
industry needs to get to as well as pathways to modernize how we produce power in this country. By
providing several different opportunities for compliance and multiple financial incentives, power plants
will have what they need to move forward with rapid emission reduction. | encourage the agency to
move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you, Dana Davis’
203

SS. American

4 Sustainable
Business

oy Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HO-OAR-2023-0072

My name is Renaud des Rosiers and I’m from Sonoma County, CA. am writing to express my, and my
organization, Amy's Kitchen’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 -
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction, | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,’
204

DS. American
iN, Sustainable
VZV) Business
Pz” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Lawrence Garwin and I’m in Palo Alto, California. | am writing to express my strong support
for the Biden administration’s proposed standards to cut climate pollution from coal- and natural gas-
fired power plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon
poilution, using the air our communities and businesses are dependent upon as a dumping ground for
far too long. if enacted the EPA’s proposal will allow us ‘to avoid 1,300 premature deaths, 800 hospital
and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days
providing up to $85 billion in net climate and public health benefits. Listen to scientists’ warnings about
the urgent need for climate action and the voices of those living near power plants most impacted by
their emissions, which are disproportionately low-income and communities of color, This critically
important step forward provides a clear end point for where the industry needs to get to as well as
pathways to modernize how.we produce power in this country. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines, Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible
standards to cut climate pollution from power plants. Thank you, Lawrence Garwin Palo Alto, California’
205

SN American
i Sustainable
Z| Business

“Se” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Sarah Quinn and I'm from Fairfield, lowa. | am to express my strong support for the Biden
administration’s proposed standards to cut climate pollution from coal- and natural gas-fired power
plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon pollution,
using the air our communities and businesses are dependent upon as a dumping ground for far too long.
If enacted the EPA’s proposal will allow us to avoid 1,300 premature deaths, 800 hospital and ER visits,
more than 300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to
$85 billion in net climate and public health benefits. Listen to scientists’ warnings about the urgent need
for climate action and the voices of those living near power plants most impacted by their emissions,
which are disproportionately low-income and communities of color. This critically important step
forward provides a clear end point for where the industry needs to get to as well as pathways to
modernize how we produce power in this country. By providing several different opportunities for
compliance and multiple financial incentives, power plants will have what they need to move forward
with rapid emission reduction. | encourage the agency to move forward with this proposal and work to ~
achieve greater cuts to pollution from more sources on the fastest possible timelines. Our climate can’t
wait, The EPA must act by early 2024 to finalize the strongest possible standards to cut climate pollution
from power plants. Thank you,' ;
206

American
Sustainable
Business
Network .

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HO-OAR-2023-0072

Enough is enough! My name is Dulanie Ellis-La Barre and I’m from Ojai, C. | am writing to express my,
and my organization, Walk Your Talk Productions', strong support for the Biden administration’s
proposed standards to cut climate pollution from coal- and natural gas-fired power plants. As we know,
fossil fuel-fired power plants are one of the largest sources of carbon pollution, using the air our
communities and businesses are dependent upon as a dumping ground for far too long. If enacted the
EPA’s proposal will allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. Listen to scientists’ warnings about the urgent need for climate
action and the voices of those living near power plants most impacted by their emissions, which are
disproportionately low-income and communities of color. This critically important step forward
provides a clear end point for where the industry needs to get to as well as pathways to modernize how
we produce power in this country. By providing several different opportunities for compliance and
multiple financial incentives, power plants will have what they need to move forward with rapid
emission reduction. | encourage the agency to move forward with this proposal and work to achieve
greater cuts to pollution from more sources on the fastest possible timelines. Our climate can’t wait.
The EPA must act by early 2024 to finalize the strongest possible standards to cut climate pollution from
power plants. Thank you,’
207

=. American
M7, Sustainable
Ya) Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Perla Ni and I’m from Menlo Park, CA. am writing to express my strong support for the
Biden administration’s proposed standards to cut climate pollution from coal- and natural gas-fired
power plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon
pollution, using the air our communities and businesses are dependent upon as a dumping ground for
far too long. if enacted the EPA’s proposal will allow us to avoid 1,300 premature deaths, 800 hospital
and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days
providing up to $85 billion in net climate and public health benefits. Listen to scientists’ warnings about
the urgent need for climate action and the voices of those living near power plants most impacted by .
their emissions, which are disproportionately low-income and communities of color. This critically
important step forward provides a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible
standards to cut climate pollution from power plants. Thank you, Perla’
208

American

Sh) Sustainable
Business
Nd Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Terrence McNally, Long Beach, CA. | want to express strong support for the Biden
administration’s proposed standards to cut climate pollution from coal- and natural gas-fired power
plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon pollution.
EPA’s proposal will allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300K
asthma attacks, 38K school absences, and 66K lost work days providing up to-'$85B.in-net climate and
public health benefits. Listen to scientists’ warnings about the urgent need for climate action and the
voices of those living near power plants most impacted by emissions, disproportionately low-income
and communities of color. By providing several different opportunities for compliance and multiple
financial incentives, power plants will have what they need to move forward with rapid emission
reduction. | encourage the agency to move forward with this proposal and work to achieve greater cuts
to pollution from more sources on the fastest possible timelines. The EPA must act by early 2024 to
finalize the strongest possible standards to cut climate pollution from power plants. Thank you,'
209

KN Sustainable

' Business
y ay Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HOQ-OAR-2023-0072 :

My name is Deborah Frangquist and I’m from San Francisco, California. | am writing to express my, and
my organization, Chosen Futures’ strong support for the Biden administration’s proposed standards to
cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where _
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must-act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants, Thank you,’
210

American
SIN Sustainable
(Vj! Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is George Naumovski and I’m from Melbourne Australia. | am writing to express my, and my
organization GNCORP, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point .for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,’
211

American

SM Sustainable
Va Business
P=” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Freek Driesenaar and I’m from Oudheusden in the Netherlands. | am writing to express my,
and my offspring’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from mare sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you, With confidence in
your moral compass, Freek Driesenaar'
212

—

OS American
NM Sustainable
9) Business
Ps” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is David Friedman and I’m from Danbury CT. | am writing to express my, and my organization,
Plantissimo LLC’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are ;
dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits, Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
‘and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,'
213

4 Sustainable
: usiness

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072 :

Lam writing to express my, and my organization, strong support for the Biden administration’s proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will
allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks,
38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and public
health benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of
those living near power plants most impacted by their emissions, which are disproportionately low-
income and communities of color. This critically important step forward provides a clear end point for
where the industry needs to get to as well as pathways to modernize how we produce power in this
country. By providing several different opportunities for compliance and multiple financial incentives,
power plants will have what they need to move forward with rapid emission reduction. | encourage the
agency to move forward with this proposal and work to achieve greater cuts to pollution from more
sources on the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to
finalize the strongest possible standards to cut climate pollution from power plants. Thank you,’
214

American
, Sustainable
' Business
Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Leon Miller-Out and I’m from Ithaca, NY. | am writing to express my, and my organization,
Singlebrook’s, strong support for the Biden administration’s proposed standards to cut climate pollution
from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon _
as a dumping ground for far too long. if enacted the EPA’s proposal will allow us to avoid 1,300
premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school
absences, and 66,000 lost work days providing up to $85 billion in net climate and public health benefits.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. This critically important step forward provides.a clear end point for where the
industry needs to get to as well as pathways to modernize how we produce power in this country. By
providing several different opportunities for compliance and multiple financial incentives, power plants
will have what they need to move forward with rapid emission reduction. | encourage the agency to
move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,'
215

BQ. American
=) Sustainable
2 Business

a” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Seth Perlman and I’m from Highmount NY. lam [writing] to express my, and my
organization, Perlman & Perlman LLP. strong support for the Biden administration’s proposed standards
to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired
power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will
allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks,
38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and public
health benefits: Listen to scientists’ warnings about the urgent need for.climate action and the voices of
those living near power plants most impacted by their emissions, which are disproportionately low-
income and communities of color. This critically important step forward provides a clear end point for
where the industry needs to get to as well as pathways to modernize how we produce power in this
country. By providing several different opportunities for compliance and multiple financial incentives,
power plants will have what they need to move forward with rapid emission reduction. | encourage the
agency to move forward with this proposal and work to achieve greater cuts to pollution from more
sources on the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to
finalize the strongest possible standards to cut climate pollution from power plants. Thank you,’
216

—

S25. American
/ AS Sustainable
NA Business

“SB Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

lam writing to express my STRONG SUPPORT for the Biden administration’s proposed standards to cut
climate pollution from coal--and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
STRONGEST possible standards to cut climate pollution from power plants. Thank you,’
217

—

S25 American

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Maria Allison and i’m from Philadelphia, PA, | am writing to express my strong support for
the Biden administration’s proposed standards to cut climate pollution from coal- and natural gas-fired
power plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon
pollution, using the air our communities and businesses are dependent upon as a dumping ground for
far too long. If enacted the EPA’s proposal will allow us to avoid 1,300 premature deaths, 800 hospital
and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days
providing up to $85 billion in net climate and public health benefits. Listen to scientists’ warnings about
the urgent need for climate action and the voices of those living near power plants most impacted by
their emissions, which are disproportionately low-income and communities of color. This critically
important step forward provides a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible
standards to cut climate pollution from power plants. Thank you, Maria Allison’ .
218

S\ American
WAV’ Business
Se” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Julien and I’m from Brooklyn, NY | am writing to express my, and my organization, Create
The Remarkable's, strong support for the Biden administration’s-proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net:climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants.most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,’
219

KN Sustainable

VN Business
way Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Neil Donnelly and ’m from Brooklyn, NY. | am writing to express my strong support for the
Biden administration's proposed standards to cut climate pollution from coal- and natural gas-fired
power plants: As we know, fossil fuel-fired power plants are one of the largest sources of carbon
pollution, using the air our communities and businesses are dependent upon as a dumping ground for
far too long. If enacted the EPA’s proposal will allow us to avoid 1,300 premature deaths, 800 hospital
and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days
providing up to $85 billion in net climate and public health benefits, Listen to scientists’ warnings about
the urgent need for climate action and the voices of those living near power plants most impacted by
their emissions, which are disproportionately low-income and communities of color. This critically
important step forward provides a clear end point for where the industry needs to get to as well as.
pathways to modernize how we produce power in this country. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible
standards to cut climate pollution from power plants. Thank you, Neil’
220

SS. American

SS Sustainable
Business

Ea” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Taj and I’m from. Warrenton in Virginia. tam writing to express my, and my small business's,
Greenvision Design, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. if enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,'
>: Business
Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Paul Zeigle and I’m from St. Louis Park, MN. | am writing to express my, and my
organization, Quality Bicycle Products, strong support for the Biden administration’s proposed standards
to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired
power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will
allow us to avoid 1,300 premature deaths, 800. hospital and ER visits, more than 300,000 asthma attacks,
38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and public
health benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of
those living near power plants most impacted by their emissions, which are disproportionately low-
income and communities of color. This critically important step forward provides a clear end point for
where the industry needs to get to as well as pathways to modernize how we produce power in this
country. By providing several different opportunities for compliance and multiple financial incentives,
power plants will have what they need to move forward with rapid emission reduction. | encourage the
agency to move forward with this proposal and work to achieve greater cuts to pollution from more
sources on the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to
finalize the strongest possible standards to cut climate pollution from power plants. Thank you,’
222

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Elric and I’m from Berkeley, CA. | am writing to express my, and my organization, OLIPOP's,
strong support for the Biden administration’s proposed standards to cut climate pollution from coal- and
natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the largest sources
of carbon pollution, using the air our communities and businesses are dependent upon.as.a'dumping
ground for far too long. If enacted the EPA’s proposal will allow us to avoid 1,300 premature deaths,
800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and 66,000 lost
work days providing up to $85 billion in net climate and public health benefits. Listen to scientists’
warnings about the urgent need for climate action and the voices of those living near power plants most
impacted by their emissions, which are disproportionately low-income and communities of color. This
critically important step forward provides a clear end point for where the industry needs to get to as
well as pathways to modernize how we produce power in this country. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible
standards to cut climate pollution from power plants. Thank you, Elric Centers’
223

American
SN Sustainable
“SE” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HO-OAR-2023- 0072

My name is Kimberly Heismann and I’m from New York, NY. | am writing to express my, and my
organization, Emotiva’s, strong support for the Biden administration’s proposed standards to cut climate
pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are
one of the largest sources of carbon pollution, using the air our communities and businesses are
dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,’
224

i N Sustainable

WIS) Business
Vee Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Reverend Jean-Luc Charles and I’m from Stamford, CT. | am writing to express my and my
church's strong support for the Biden administration’s proposed standards to cut climate pollution from
coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. If enacted the EPA’s proposal will allow us to avoid 1,300
premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school
absences, and 66,000 lost work days providing up to $85 billion in net climate and public health benefits.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. This critically important step forward provides‘a clear end paint for where the
industry needs to get to as well as pathways to modernize how we produce power in this country. By
providing several different opportunities for compliance and multiple financial incentives, power plants
will have what they need to move forward with rapid emission reduction. | encourage the agency to
move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,'
225

—

~\ Sustainable

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Janet Kahn and I’m from Burlington, VT. lam writing to express my strong support for the
Biden administration’s proposed standards to cut climate pollution from coal- and natural gas-fired
power plants, As we know, fossil fuel-fired power plants are one of the largest sources of carbon
pollution, using the air our communities and businesses are dependent upon as a dumping ground for
far too long. If enacted the EPA’s proposal will allow us to avoid 1,300 premature deaths, 800 hospital
and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days
providing up to $85 billion in net climate and public health benefits. Listen to scientists’ warnings about
the urgent need for climate action and the voices of those living near power plants most impacted by
their emissions, which are disproportionately low-income and communities of color. This critically
important step forward provides a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible
standards to cut climate pollution from power plants. Thank you,’
226

American
. SM Sustaina ble
\ usiness
“Slr” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Charles White and I’m from Worton, MD. | am writing to express my strong support and my
companies support for the Biden administration’s proposed standards to cut climate pollution from
coal- and natural gas-fired power plants. As we know, fossil fuel-fired power plants are one of the
largest sources of carbon pollution, using the air our communities and businesses are dependent upon
as a dumping ground for far too long. If enacted the EPA’s proposal will.allow us to avoid 1,300
premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000 school
absences, and 66,000 lost work days providing up to $85 billion in net climate and public health benefits.
Listen to scientists’ warnings about the urgent need for climate action and the voices of those living near
power plants most impacted by their emissions, which are disproportionately low-income and
communities of color. This critically important step forward provides a clear end point for where the
industry needs to get to as well as pathways to modernize how we produce power in this country. By
providing several different opportunities for compliance and multiple financial incentives, power plants
will have what they need to move forward with rapid emission reduction. | encourage the agency to
move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the
strongest possible standards to cut climate pollution from power plants. Thank you,'
227

ES. American

i ND\, Sustainable
WIS Business

“Se” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Leola Specht and I’m from Rhinebeck, NY. | am writing to express my, and my
organization,JSA Sustainable Properties’s, strong support for the Biden administration’s proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. If enacted the EPA’s proposal will
allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks,
38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and public
health benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of
those living near power plants most impacted by their emissions, which are disproportionately low-
income and: communities of color. This critically important step forward provides a clear end point for
where the industry needs to get to as well as pathways to modernize how we produce power in this
country. By providing several different opportunities for compliance and multiple financial incentives,
power plants will have what they. need to move forward with rapid emission reduction. | encourage the
agency to move forward with this proposal and work to achieve greater cuts to pollution from more
sources on the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to
finalize the strongest possible standards to cut climate pollution from power plants. Just as important,
we must immediately move money from funding environmentally destructive farming practices to
conversion to regenerative agriculture practices that have a net positive environmental impact vs the
detrimental which is the norm now. To avoid a permanently unstable (we can expect more and more
severe fire, flood, wind, etc. weather events if we don't act now) climate, we need to reduce methane,
refrigerant and CO2 emissions and increase biodiversity and nature soil regeneration now and forward.
228

Sa American

ia \\ Sustainable
A ay! Business

be” Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is David Way and I’m from Lincoln, RI. | am writing to express my, and my

organization, Vanderbilt Financial Group DBA Greenvest’s, strong support for the Biden administration’s .
proposed standards to cut climate pollution from coal- and natural gas-fired power plants. As we know,
fossil fuel-fired power plants are one of the largest sources of carbon pollution, using the air our
communities and businesses are dependent upon as a dumping ground for far too long. If enacted the
EPA’s proposal will allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than
300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days providing up to $85 billion
in net climate and public health benefits. Listen to scientists’ warnings about the urgent need for climate
action and the voices of those living near power plants most impacted by their emissions, which are

dis proportionately low-income and communities of color. This critically important step forward
provides a clear end point for where the industry needs to get to as well as pathways to modernize how
we produce power in this country. By providing several different opportunities for compliance and
multiple financial incentives, power plants will have what they need to move forward with rapid
emission reduction. | encourage the agency to move forward with this proposal and work to achieve |
greater cuts to pollution from more sources on the fastest possible timelines. Our climate can’t wait:
The EPA must act by early 2024 to finalize the strongest possible standards to cut climate pollution from
power plants.

Thank you,

David Way
229

BX. American
SH Sustainable
2 Business
a’ Network

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is. gal nahum and I’m from Clearwater, FL. | am writing to express my, and my
organization,CLEAN-AIR (electric-filter)’s, strong support for the Biden administration’s proposed
standards to cut climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-
fired power plants are one of the largest sources of carbon pollution, using the air our communities and
businesses are dependent upon as a dumping ground for far too long. if enacted the EPA’s proposal will
allow us to avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks,
38,000 school absences, and 66,000 lost work days providing up to $85 billion in net climate and public
health benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of
those living near power plants most impacted by their emissions, which are disproportionately low-
income and communities of color. This critically important step forward provides a clear end point for
where the industry needs to get to as well as pathways to modernize how we produce power in this
country. By providing several different opportunities for compliance and multiple financial incentives,
power plants will have what they need to move forward with rapid emission reduction. | encourage the
agency to move forward with this proposal and work to achieve greater cuts to pollution from more
sources on the fastest possible timelines. Our climate can’t wait. The EPA must act by early 2024 to
finalize the strongest possible standards to cut climate pollution from power plants. Thank you, pr.
nahum we must act now i got a very radical solution to our CO2 emissions just turn them to 02 by using
conducted Direct Current with my electric filter https://youtu.be/qkoPmBPmeCo'
230

&. American
IT, Sustainable

a) Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Lilliane LeBel and I’m from Temple, NH. |! am writing to express my, and my
organization,LeBel Marketing’s, strong support for the Biden administration’s proposed standards to cut
climate pollution from coal- and natural gas-fired power plants. As we know, fossil fuel-fired power
plants are one of the largest sources of carbon pollution, using the air our communities and businesses
are dependent upon as a dumping ground for far too long. !f enacted the EPA’s proposal will allow us to
avoid 1,300 premature deaths, 800 hospital and ER visits, more than 300,000 asthma attacks, 38,000
school absences, and 66,000 lost work days providing up to $85 billion in net climate and public health
benefits. Listen to scientists’ warnings about the urgent need for climate action and the voices of those
living near power plants most impacted by their emissions, which are disproportionately low-income
and communities of color. This critically important step forward provides a clear end point for where
the industry needs to get to as well as pathways to modernize how we produce power in this country.
By providing several different opportunities for compliance and multiple financial incentives, power
plants will have what they need to move forward with rapid emission reduction. | encourage the agency
to move forward with this proposal and work to achieve greater cuts to pollution from more sources on
the fastest possible timelines. Cutting climate pollution is both popular with the public and critical to
the success of the United States economy. Our climate can’t wait. The EPA must act by early 2024 to
finalize the strongest possible standards to cut climate pollution from power plants.
231

SS. American
4 Business

Docket Number: New Source Performance Standards for GHG Emissions from New and Reconstructed
EGUs; Emission Guidelines for GHG Emissions from Existing EGUs; and Repeal of the Affordable Clean
Energy Rule EPA-HQ-OAR-2023-0072

My name is Mary Bachhuber and I’m from Middleton, WI. | am writing to express my strong support for
the Biden administration’s proposed standards to cut climate pollution from coal- and natural gas-fired
power plants. As we know, fossil fuel-fired power plants are one of the largest sources of carbon
pollution, using the air our communities and businesses are dependent upon as a dumping ground for
far too long. If enacted the EPA’s proposal will allow us to avoid 1,300 premature deaths, 800 hospital
and ER visits, more than 300,000 asthma attacks, 38,000 school absences, and 66,000 lost work days
providing up to $85 billion in net climate and public health benefits. Listen to scientists’ warnings about
the urgent need for climate action and the voices of those living near power plants most impacted by
their emissions, which are disproportionately low-income and communities of color. This critically
important step forward provides a clear end point for where the industry needs to get to as well as
pathways to modernize how we produce power in this country. By providing several different
opportunities for compliance and multiple financial incentives, power plants will have what they need to
move forward with rapid emission reduction. | encourage the agency to move forward with this
proposal and work to achieve greater cuts to pollution from more sources on the fastest possible
timelines. Our climate can’t wait. The EPA must act by early 2024 to finalize the strongest possible
standards to cut climate pollution from power plants. The EPA is sincerely urged to develop policy and
standards for businesses to reduce emisions which are found to causeClimate Change.
232

=. American
SN Sustainable

' Business
“Wiz” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a-clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits, We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. :

Thank You,

Tim Greiner
233

ES. American
SIN Sustainable

WIN] Business
ee Network

A

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

.- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation:

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Heidi Sanborn
234

NN Sustainable

SN
ay)

Wes

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources:‘and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460 ;

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
Job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. :

Thank You,

Dominik Eckenstein
235

#2 American
NI Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Kris Coperine
236

iS. American
NM Sustainable

7’ Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation. .

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive-economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Saab Lofton
237

eS. American
KIN Sustainable

WAZ) Business
ee” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to. reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Rinaldo Brutoco
238

=. American
A. Sustainable

7") Business
ay usi

2” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed'to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. ;

Thank You,

JOHN PAHSSEN
239

ES. American

NIN Sustainable

' Business
Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and ‘their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the .
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future, Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Martin Wolf
240

eo. American

<M Sustainable

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Adrian Gershom
241

= American
KIN Sustainable

NV Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits, We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Joe Womack
242

SS =. American
ia SIN Sustainable

\

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has-negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jake Elliott
243

SS. American

Sustainable
usiness

De" Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Sandra Stewart
244

\. American .
SA Sustainable

27! Business

Network.

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks ;

+ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control’technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Emma Jacobs
245

SN American
SM Sustainable
Business

“Si” Network

Docket Number: ‘Standards of Performance for New, Reconstructed; and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency {EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. ;

Thank You,

lleana Vasquez
246

x oN American
V2) Business
“Sl”. Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HO-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to. sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Storm Cunningham
247

\ American -
(SYA) Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the heaith of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. :

Thank You,

Christopher Miller
248

SN American
NIN Sustainable

ay Business

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the heaith of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people, We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will

push private investment and foster greater innovation.

Thank You,

Timon Malloy
Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Nancy Romer
250

DS American |

SA, Sustainable
Business

be” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Talia Manning
251

SS. American
127 Business

“Wi” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities sand ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Bram Kleppner
252

BS. American
<\\ Sustainable
Zvi Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan, .

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Maren Keeley
253

NN American

st Sustainable
ay

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Pravent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Abigail Rome
254

American
» Sustainable
777 Business
| 4 Network |

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being-directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

William Russell
255

SS. American
2 Business

Ea” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and:
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

David Schreiber
256

N American
\\ Sustainable

2’ Business
ay Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems. ,

Taking action to reduce the impacts of methane will:
- Mitigate climate risks
- Prevent continued harm to local communities and ecosystems
_~ Reduce pricing uncertainty and market volatility
~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jared Meyers
257

25 American
NIM Sustainable

W ay Business

“SEs” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA} to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Josh Kofflin
258

A Sustainable
‘7’ Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems. ,

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation,

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Gina Weatherup
259

RN Sustainable
ay! Business.

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HO-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet andthe .
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Roger Pritchard
260

American
SN Sustainable
' Business
ar Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people, We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems. ;

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Stephanie Klotz
261

=. American
Sd, Sustainable
(S27! Business

=

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation,

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Pete Dignan
262

Vy Business

a

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy.and strong regulation that will
push private investment and foster greater innovation.

Thank You,

sidney amster
263

' Business

‘eer Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation,

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to'transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Barb Frances
264

#4. American

Vay’ Business
Ev” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and'their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems,

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation,

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Michael Pirron
265

#@ Ss American

23’ Business
“Ser Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~-Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and .
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits, We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Mary Weyker
266

American
> Sustainable
NSE’ Network

——

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HOQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Charles Wolfe
267

: BS, American
NM Sustainable

ay Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future, Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
jeb creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from. an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jarrod Russell
268

1S. American
SA, Sustainable

Business
Va" Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modifiéd Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HO-OAR-
2021-0317-1460 .

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

+ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S, must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Ray Cooper
269

nN American ©

> , Sustainable
yi! Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Marie Mainil
270

—

A Sustainable

AN ' Business

y

w

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

'- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Ajax Greene
271

2 American
Ky Sustainable
Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review! EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation: Benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Richard Lawton
272

SS. American
Sa, Sustainable
Wei ay! Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the -
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. :

Thank You,

Elizabeth Whitlow
273

\ American

Ne usiness

Docket Number: "Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses.and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems. :

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

‘The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Sara Olsen
274

SN Sustainable
' Business
Ky Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and ,
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a’super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

~ Prevent continued harin to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and. strong regulation that will
push private investment and foster greater innovation.

Thank You,

Lynn Nadeau
275

is. American
SN Sustainable.
' Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) ta
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

« Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Simone Schmidt
276

American
<i Sustainable
“Se” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460 :

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) ta
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems:

Taking action to reduce the impacts of methane will:

- Mitigate climate risks ,

~ Pravent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation,

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions —
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

William Paolillo
277

SS. American

Soy Sustainable
Business

Bev Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions.
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Emma Jacobs
278

SM Sustainable
S20) Business
“SE” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains, We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jeff Kletter
279

2. American
\\\ Sustainable
! Business
“Ea” Network

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources.and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jared Meyers
280

BQ. American
AN Sustainable

72 Business
Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility :
~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits, We believe the U.S. must work actively to reduce its greenhouse gas emissions
and ‘to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

diane keefe
281

American
EN Sustainable
Business

“wiz” ~ Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and'our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You, . i \

Gracen Cloud Levine
282

=. American

3) Sustainable
Business.

Sz’ Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review! EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites; an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. ° ,

Thank You,

Daniel OBrien
283

a, Sustainable

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. ;

Thank You,

Shannon Pendleton
284

\ American

NY ; Sustainable

' Business
NS Network |

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits, We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Glenn Schiffbauer
285

SN American
“Se” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is asuper pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Keyanna Silverman
286

American

RN Sustainable

vee? Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HOQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA} to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility ;

- Regulate the harmful impacts of methane to stimulate investment and innovation. .

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits, We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Kathleen Curtis
287

nN American
S\ Sustainable
ea” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HO-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an. end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Nancy Felton
288

\ American

SN, Sustainable

' Business
Network

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OQAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems,

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired-extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Miles Lazar
289

LEE. American
SN Sustainable

‘ oy Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

David Kline
290

American
KN Sustainable
ay! Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review! EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jim Bates
291

SN American
SN, Sustainable

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Alan Peterson ©
292

LS American

oo) Sustainable
Business

‘eae’ Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people, We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jared Meyers
293

£25 American
27 Business

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation,

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions |
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Dan Kirslis
294

N American
: Business

Se” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector-Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. ;

Thank You,

Jared Meyers
295

i

Ss American
SA, Sustainable

' Business
NS” Network

[Ss

K

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency {EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to-transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. ‘

Thank You,

Shan Magnuson
296

#2. American
4) Sustainable
VXVAV! Business
“SS Network

\

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and -
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems. :

Taking action. to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation:

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. .

Thank You,

Amy Bergman
297

ES. American
sustainable
42 Business |
Ez’ Network

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review! EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.’

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

John Gage
298

\ American

, Sustainable
| Business
Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-

Dear EPA Administrator Regan,

Methane is.a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions .
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Edward Savage
299

American

ANA Business
NS Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

-- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S, must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Helen Kessler
300

[> BA American
So Sustainable
(NAV) Business
“Se” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Ashley Duque Kienzle
301

OS. American
SN Sustainable
ay Business

WS Network

=a

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: oil and Natural Gas Sector Climate Review’ EPA-HO-OAR-
2021-0317-1460.

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. :

Thank You,

Gordon Deane
302

SS. American
usiness

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HOQ-OAR-
2021-0317-1460 :

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people, We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You, -

linda Behnken
303

Va) Business
Network

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable-energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from/an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Dr Kenneth R Pelletier
304

American

' Business

Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agericy (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired. extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S, must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. .

Thank You,

Jerry Rivers
305

52. American
SIM Sustainable

“SE” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses.and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Deborah Gavrin Frangquist
306

=. American
NIN Sustaina ble

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Laura Neish
307

—

=\ American
KIN Sustainable
INIA) Business
“Wer Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks ,

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. ‘

Thank You,

Rebecca Canright
308

American

P| Sustainable
vey Business

Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review! EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution arid our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Elric Centers
309

SX. American

ca Sustainable
usiness

No Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jared Meyers
310

SN American
, Business
‘eer Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review! EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Anne Robertson.
311

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Michelle Holliday
312

iS. American
FY \ NM Sustainable
“SE” Network

Docket Number: 'Staridards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted. by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits, We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jim Loveland
313

American

cM Sustainable

7’ Business
‘ee y Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Adrienne Wald
314

SA, Sustainable
IZ) Business
Ba” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jeremy Smithson
315

American
ray Sustainable
“Se” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-

Dear EPA Administrator Regan, -

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits, We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Karla Kavanaugh
316

i NN Sustainable

ee Network

A

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460 ;

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Mark Canright
317

4. American
nN, Sustainable

NS Network

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. ;

Thank You,

Michael Peck
318

i Sustainable

PON
V2) Business
say Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Rachel Robillard
319

American
, Sustainable
’ Business
Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

michele risa
320

American

I \ SN Sustainable
WS L\/, ay Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people, We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Linda Romano
321

BS. American
ia) Business

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Stephen Wyman
322

Ss. American
NN Sustainable:

=
Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and

Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review! EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the —
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Theodora Skeadas
323

sz American

(AX, Sustainable
VISA Business

SE Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jared Meyers
324

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HO-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems. :

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility ;

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Scott Andersen
325

—

NJ, Sustainable
2)! Business

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks .

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions _
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. .

Thank You,

timothy stein
326

oy Sustainable
27 Business

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane isa super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility .

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

thalia lubin
327

SS. American
RN Sustainable
* Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review! EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting-the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane poilution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Seth Perlman
328

PB. American

NN Sustainable
“Wea” Network

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S, must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Christopher Overholt
329

American

usiness

| ae” Network

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources.and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems. ,

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility :

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Bernardo Alayza Mujica
330

WV) Business
“Sze” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end-to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work-actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Stephanie Reader
331

American

NO Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people, We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future, Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation:

The development and implementation of meaningful policy that supports. control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits, We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Susan Kask
332

American
RN Sustainable
a Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

A.L. Steiner
333

25. American
KN Sustainable

7’ Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and

_ businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Emma Jacobs
334

VZV) Business

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility .
- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices:such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Derek Gendvil ©
335

oy Sustainable

~ Business
=” Network

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation,

The development and implementation of meaningful policy that supports contro! technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Douglas Campion -
336

American
N Sustainable
' Business
Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits, We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Dann Carnes
337

iS. American
SUNN Sustainable
“i” Network

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sourcés and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and-our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Brian Caneda
338

—

2. American
Business
No Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action:to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

tim brainerd
339

45 American
‘47’ Business

Docket Number: ‘Standards of Performance for New, Reconstruéted, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas. emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Michael Green
340

ac) Sustainable
usiness

ae” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures.a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Brenda Michaels
341

American
KN Sustainable
S27’ Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action.in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation,

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Leslie Sheridan
342

\ usiness

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

William Wallin
343

ft TN American
i SA Sustainable

NN B
ee Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment'and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Janice Brown
344

BS. American
UNA)! Business
NS” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

+ Reduce pricing uncertainty and market volatility :
~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Suzanne Sokolov
345

eS. American
RN Sustainable

say Business

Network .

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people, We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Terry Gips
346

Docket Number: ‘Standards of Performance for New, Reconstructed; and Modified Sources and-
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and'their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:
~ Mitigate climate risks
*. Prevent continued harm to local communities and ecosystems
- Reduce pricing uncertainty and market volatility
- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous. practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Mitch Ratcliffe
347

SS. American
Ji Business

i Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S, must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Michael Friedman
348

American
Sustainable
ji Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment ahd innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Rebekah Miel
349

: American
Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment.and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

James Dawson
350

ES. American
+ Sustainable
22 Business
Ea” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and. Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility .

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports.a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. .

Thank You,

Lauren Hale
351

S25. American
ZV) Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts.of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jared Meyers
352

American
RN Sustainable

we’ Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Prasad Jaladi
353

#25 American
KO sustainable
2 Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
“methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. :

Thank You,

Christopher Loch
354

SS. American
% Business
Ea” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

JoAnn Hanson
355

American
i Sustainable
' Business
Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review! EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

-~ Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Kathryn Kelly
356

KN Sustainable
a’ Network

ff

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jennifer Nichols
357

American

IS Sustainable
Ay’ Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Barry Cik
358

DS. American
4 Sustainable
Business

Ea” Network

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility :

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Martin Wolf
359

AS

a Sustainable.

Business
Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.:

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Madelyn George
360

SN American
RN Sustainable
Vay)! Business
B=’ Network

Docket Number: ‘Standards. of Performance for New, Reconstructed, anid Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460 .

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S, must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

MaritA® Bali
361

25. American
SN Sustainable
Yay! Business

=—

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean’
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility ; :
- Regulate the harmful impacts of methane to stimulate investment and innovation. \

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Chelsea Souter.
362

=. American
Sy Sustainable

Z| Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health‘of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems. :

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits.. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Bill Russell
363

SN Sustainable

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies; cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Steven Adams
364

| i; Sustainable

Way Business

Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people, We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts.of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. ;

Thank You,

Anna M Lyles
365

American
Sh Sustainable
a Z| Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S, must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Michael Whalen
366

J American
SN Sustainable
KV Business
Network

ew

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity It
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

ULY CHEHRAZI
367

oN American
SM Sustainable
' Business
“WE” ~- Network

ial

\

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions.
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Pat Davis
368

ZS

iN American

44) Business
ey Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are. passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Taj DeHart
369

American
SN Sustainable
' Business
<i” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review! EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is.a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains, We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to. make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future.. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies; cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. :

Thank You,

Marilyn Bruno
370

i RN Sustainable
ISN Business
“Slr Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR- °
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains, We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility :

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You, -

Kristine Waldren
371

7S. American
SIN Sustainable
(SAV)! Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will-deliver the greatest long-term economic and
job creation benefits. We believe the U.S, must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Lucy V Hitchcock
372

eS. American

#

ee? Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-.
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

jon spar
373

Zi) Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review" EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will: _

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility.

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S, must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Shaun Paul
374

SO] Sustainable
A Business
‘eer Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts.on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks ;

- Prevent continued harm to local:communities and ecosystems

- Reduce pricing uncertainty and market volatility .

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. .

Thank You,

George Law
375

SN American
VAAN Sustainable

ey Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks _

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation,

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Katharine King
376

—

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Barry Cik
377

% American
N Sustainable

ay! Business
ey Network

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR- _
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Allen Bromberger
378

JS American
sustainable
2 Business
Pa” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan, -

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks :

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation,

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. .

Thank You,

Cheryl Spector
379

American

= Sustainable
car Network |

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Mark Hayduke Grenard
380

ey Business

Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and.
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HOQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the heaith of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must.work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Dana Weintraub
381

Business
Network

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

+ Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic. and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Katie Lucca
382

sa American
SN, Sustainable

Docket Number: Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation,

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. .

Thank You,

Natasha Winnik
383

y- NN American
SA, Sustainable

(2) Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems. :

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. :

Thank You;

Karen Berger
384

SN American |
Say Sustainable

No Network |

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:
- Mitigate climate risks
' = Prevent continued harm to local communities and ecosystems
- Reduce pricing uncertainty and market volatility
- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jared Meyers
385

=. American

2 Business

“Se” Network

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people, We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems,

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Yoca Arditi-Rocha
386

eS. American

Yay) Business
Ba’ Network .

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460 ,

Dear EPA Administrator Regan,

Methaiie is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet-and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean .
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Robert OFM Cap.
387

oN American

INAV) Business
Nae! Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Christian Grieco
388

_ American
Sustainable
i Business
Network

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation:

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
‘supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jina Penn-Tracy
389

eS. American

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HO-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions -
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Katherine DiMatteo
390

aN American
Hy Sustainable
| 7 Business
“Se” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future, Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S, must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Elizabeta Stacishin--
391

\ American
\Z’ Business

\

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’. EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and-ecosystems

- Reduce pricing uncertainty and market volatility :
~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Linda Beitz
392

rN American
A! Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460 ;

Dear EPA Administrator Regan, .

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems. ,

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Harvy Simkovits
393

/ A 1 Sustainable
Ev” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation:

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S, must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jim Holland
394

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review! EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems. .

Taking action to reduce the impacts of methane will:

- Mitigate climate risks .

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility ;
~ Regulate the harmful impacts of methane to stimulate investment and innovation. —

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits, We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jared Meyers
395

[SS American
7 Business

“Se” Network

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review! EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Linda Adams
396

—

eS. American
AN Sustainable
Vays Business
“Se” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems -

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S, must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Alexa Manning
397

American
, Sustainable
J) Business
Network

\

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition. away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Anna Sampson
398

SS. American
SIN Sustainable
ay! Business
“22” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Judith Borcz
399

American

' Business
Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
busiriesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards.a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems,

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

+ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation,

Thank You,

Mark Kleinschmit
400

SS. American
AM Sustainable

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has. negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the.
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate. climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility .
- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Reena Gordon
401

22. American
NN Sustainable
IV Business
Ea” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460 :

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retifed extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Tim Wheeler
402

eS. American
M7, Sustainable
‘i Business

Was

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460 .

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations.are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its. greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Justin Overdevest
403

=. American
ay Sustainable
WN Business

Docket Number: 'Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HO-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean .
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Rob Spears
404

—

SS. American
i aN Sustainable
A / ' Business
“Ses Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is.a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Phillip Gioia
405

BS. American

Ay

i

“Ss Network
Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and

Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions ‘
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. . :

Thank You,

Jill Matteson
406

SS. American
+ Sustainable
‘27’ Business
Siz” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HOQ-OAR-
2021-0317-1460 .

. Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S, must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jana Gastellum
407

= American

A, Sustainable
' Business

P=” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Thalia Venerable -
408

PS. American
TZ)! Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460 .

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:
- Mitigate climate risks
- Prevent continued harm to local communities and ecosystems

_+ Reduce pricing uncertainty and market volatility ;
- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. : :

Thank You,

Gordon Rands
409

American

EN Sustainable

VA Business
“Se” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation. —

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Gina Hardin
410

<5 American

S| Sustainable
7 Business

Be” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks :

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and |
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Elizabeth Arnold
411

\ American |
/\\ Sustainable
\' Business
Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition.away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Robert Fingerman
412

American .

y usiness
Ney Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Karen Nelson
413

= American
SN Sustainable
Ea’ Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the inipacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Susan Perez
414

American
\ Sustainable

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Charlotte Watts
415

American

; Sustainable
Business
Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460 i.

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Maureen Vagnini
416

J, Sustainable
ZV! Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Emily Schumacher
417

eS. American
NIN Sustainable

ZV} Business
‘ee Network’

Docket Number: Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

’ Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Paul Wellin
418

SS. American
St Sustainable
227) Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards.a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

ferris kawar
419

SN Sustainable
AY) Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane isa super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty.and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation,

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits, We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Karen Ribeiro
420

SIN Sustainable

7’ Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are. being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility :
- Regulate the harmful impacts of methane to stimulate investment and innovation. :

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Zach Bernstein
421

NIN Sustainable
ray! Business
Ea” Network

LN. American

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems. :

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Adele Mehta
422

<N American
SN Sustainable

Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Janis Hallowell
423

ES. American

+ Sustainable

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA} to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

James Elder
424

‘VA Business
“We” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. ‘Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits, We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Emily Snyder
425

2°. American

“Se” Network

Docket Number: Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule. and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems. :

Taking action to reduce the impacts of methane will:

~- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility .
- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Margaret Barbero
426

eS. American

AS, Sustainable
AV Business

Be” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and ~
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to _
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future, Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and ©
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits: We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through-public policy and strong regulation that will
push private investment and foster greater innovation. :

Thank You,

Amy Hansen
427

Jims. American

ie a4 Sustainable
usiness

NO Network

a

Docket Number: Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S, must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Ruth Brennan
428

—

AIM Sustainable

12 Business
a Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of.people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule.and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks _

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Joseph Pepe
429

BS. American

usiness

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these’ regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems. .

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits, We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. :

Thank You,

Susan Witzel
430

i< eS. American
NIN Sustainable

oy Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic.and
job creation benefits. We believe the U.S, must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Joseph Ponte
431

a SN American

VIN a Sustainable
i Business

“Sil”. Network

Docket Number: 'Standards of Performance for New, Reconstructed, arid Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review! EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies,.cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Chad Dyer
432

(SS. American
We usiness
“le” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and ;
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development.and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Scott Simmons
433

\\ Sustainable

” Network

\

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HO-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Josephus de Groot
434

2S. American
AN Sustainable

‘ NO Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review" EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits, We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Bryan Law
435

“ American
A, Sustainable

cy Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits, We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Melanie McDermott
436

yy Business

7. American

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA} to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. ;

Thank You,

Zachary Dolan
437

LEE American
i Sustainable
a” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices. such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Deb Shannon
438

—

eS. American

A, Sustainable
(A) Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460 .

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of peaple, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation,

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away. from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

David Wilcox
439

KUN, Sustainable
| Business

Pa’ Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

John Hugg
440

BS. American
\, Sustainable
‘7’ Business
Ee” Network

IV

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action.to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

+ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. ;

Thank You,

John Maus
441

oN American
RN Sustainable
ay Business
a” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks.

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Alan Johnson
442

SM Sustainable

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future, Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems. ‘

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. ,

Thank You,

Kaneisha Lewis
443

LS American

\ <7) Business
Nee Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people, We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. :

Thank You,

Jessica Caron
444

\\ Sustainable

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review! EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S, must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Tori Wilder
445

American
Si Sustainable

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is.a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such.as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Matt Christianson
446

La American
SN Sustainable
CVA Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460 |

Dear EPA Administrator Regan,

Methane is:a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a:clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Susanne Hesse & Doug Dyer
447

SN American
\\ Sustainable
Ba” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks :

- Prevent continued harm to local communities and ecosystems.

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Caroline Pryor
448

eS. American
mee Sustainable

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures. a meaningful transition towards a clean
and sustainable energy future.. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems. :

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility .
- Regulate the harmful impacts of methane to stimulate investment and innovation..

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You, -

Fran Aguirre
449

Si Sustainable
IZ) Business
Sle” Network

Docket Number: Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports:control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. :

Thank You,

Liz Lowry
450

2. American
/ = Sustainable
<2) Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility:

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Tammara Wolfgram
451

American
RN Sustainable
zy Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks .

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its.greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Cathy Cowan Becker
452

(7) Business
Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is:a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Peter Kirby
453

SSS American

Ko] Sustainable
Vay! Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people; and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and —
supports a just transition to. sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Susan Peirce
454

i Sustaina ble
: ’ Business
“SU” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources. and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is.a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks ;

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Venedel Herbito
455

BS. American
KN Sustainable

“X72 Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer. alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You, ©

Morley Schloss
456

SS. American
\\ Sustainable
(2) Business
“Sl” Network

Was

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Earl Switzer
457

SN American

MY Sustainable
Business

Ba’ Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

+ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy.sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Sister Joan Agro.
458

2 Sustainable
Business

ai

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains, We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S, must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Jason McClain
459

American
Sh, Sustainable
227) Business
“SE” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

On behalf of GAEA and all their inhabitants, | urge you to adopt the new regulations for methane
atmospheric poisons. Thank you Methane is a super pollutant that has negative impacts on the
environment, the health of people, and businesses and their supply chains. We need action from the
Environmental Protection Agency (EPA) to ensure that these regulations are passed to make meaningful
action in protecting the planet and the people. We support the EPA draft rule and believe it ensures a
meaningful transition towards a clean and sustainable energy future. Business.and Supply chains are
being directly and negatively impacted by methane pollution and our community supports strong policy
action and the investment opportunity it will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Michael Whalen
460

SN American

py Sustainable
' Business

Docket Number: "Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a major pollutant that threatens life on earth. We need action from the Environmental
Protection Agency to pass regulations that protect our planet.

Thank You,

Steve Kaye
461

SN American
I, Sustainable
Z| Business

fi

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources.and ©
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future, Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

~ Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank you in advance,

Nancy Sagar
462

American
CN Sustainable

KV Business
Sz” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people,
businesses, and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
-and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Veronica Grant
463

ee Sustainable
2 Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility ;

- Regulate the harmful impacts of methane to stimulate investment and innovation. —

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits, Allowing this methane pollution is not only an unfair subsidy to those energy
producers, it is a missed opportunity to address emissions. Active arid new regulation is one of many
efforts that is needed to address climate change. We believe the U.S. must work actively to reduce its
~greenhouse gas emissions and to transition away from an extractive economy through public policy and
strong regulation that will push private investment and foster greater innovation.

Thank You,

Brian Jerose
464

Js American

SN Sustainable

727’ Business
en Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

We have very serious air pollution problems in Colorado with oil and gas fracking and methane leaks
being very important contributors to our greenhouse gas emissions and the associated volatile organic
compounds with our non-attainment status for ozone on the Front Range of Colorado. Methane is a
super pollutant that has negative impacts on the environment, the health of people, and businesses and
their supply chains. We need action from the Environmental Protection Agency (EPA) to ensure that
these regulations are passed to make meaningful action in protecting the planet and the people. We
support the EPA draft rule and believe it ensures a meaningful transition towards a clean and
sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems. ‘

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic.and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Leslie Glustrom
465

Za American
Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and

Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

lam a pediatrician in California seeing first-hand the impacts of the climate crisis on child health.
Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

~ Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation:

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We-believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation.

Thank You,

Amanda Millstein
466

Ha American
ia Sustainable
“WAV Business

“= Network

\

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Short term warming will be the key to how much heating we experience before we end CO2 emissions
and begin to actively remove CO2. Methane causes 80 times the warming of CO2 when first emitted and
along with nitrogen compounds is responsible for half of the actual warming causing climate chaos now.
We need to urgently cut the portion of CH4 that we can control, before feedback causes more runaway
emissions we can't. ‘

Thank You,

Jim Fournier
467

% American
I Sustainable
' Business

Ez” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas-Sector Climate Review' EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

| live in the fastest climate-warming county in the entire nation, due in part to the extensive and aging
oil industry, with methane flaring and leaking wells. | have worked documenting the agricultural
industry practices for the last 20 years. The critical need to end or greatly reduce CAFOs has never been
greater, due to the methane pools and feediot pollution, environmental and physical health impacts on
human and animal health. Methane is a super pollutant that has negative impacts on the environment,
the health of people, and businesses and their supply chains. We need action from the Environmental
Protection Agency (EPA) to ensure that these regulations are passed to make meaningful action in
protecting the planet and the people. We support the EPA draft rule and believe it ensures a meaningful
transition towards a clean and sustainable energy future. Business and Supply chains are being directly
and negatively impacted by methane pollution and our community supports strong policy action and the
investment opportunity it will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks .

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility ;
- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. Thank you, Dulanie Ellis-La Barre Walk Your Talk
productions’

Thank You,

Dulanie Ellis-La Barre
468

SN American
24° Business
“Se” Network

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to. sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private.investment and foster greater innovation.

Thank You,

David Jaber
469

const SS

SS. American

Business
ee Network

Docket Number: Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

~ Mitigate climate risks

- Prevent continued harm to local communities and ecosystems

- Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. *Finally, the announced regulation would eliminate 36 million tons of *methane
emissions from oil and gas operations by 2035 a€” more than the amount of carbon dioxide emitted
from all coal-fired power plants in a single year! We believe the U.S. must work actively to reduce its
greenhouse gas emissions and to transition away from an extractive economy through public policy and
strong regulation that will push private investment and foster greater innovation.

Thank You,
470

S\ American
NN Sustainable

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

Methane is a super pollutant that has negative impacts on the environment, the health of people, and
businesses and their supply chains. We need action from the Environmental Protection Agency (EPA) to
ensure that these regulations are passed to make meaningful action in protecting the planet and the
people. We support the EPA draft rule and believe it ensures a meaningful transition towards a clean
and sustainable energy future. Business and Supply chains are being directly and negatively impacted by
methane pollution and our community supports strong policy action and the investment opportunity it
will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks :

- Prevent continued harm to local communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. We believe the U.S. must work actively to reduce its greenhouse gas emissions
and to transition away from an extractive economy through public policy and strong regulation that will
push private investment and foster greater innovation. Thank you, Rob’

Thank You,

Robert Kippel
ay} Business

Docket Number: ‘Standards of Performance for New, Reconstructed, and Modified Sources and
Emissions Guidelines for Existing Sources: Oil and Natural Gas Sector Climate Review’ EPA-HQ-OAR-
2021-0317-1460

Dear EPA Administrator Regan,

All pollution privatizes profits and socializes costs to society and Nature. Pollution means companies fail
to believe and operate in a robust market, because the price fails to reflect the actual prices to all
stakeholders. It is unacceptable for methane to be leaking from ordinary business of companies along
their supply chain and the operation of their facilities. Methane is a super pollutant that has negative
impacts on the environment, the health of people, and businesses and their supply chains. We need
action from the Environmental Protection Agency (EPA) to ensure that these regulations are passed to
make meaningful action in protecting the planet and the people. We support the EPA draft rule and
believe it ensures a meaningful transition towards a clean and sustainable energy future.. Business and
Supply chains are being directly and negatively impacted by methane pollution and our community
supports strong policy action and the investment opportunity it will create for safer alternative systems.

Taking action to reduce the impacts of methane will:

- Mitigate climate risks

- Prevent continued harm to focal communities and ecosystems

~ Reduce pricing uncertainty and market volatility

- Regulate the harmful impacts of methane to stimulate investment and innovation.

The development and implementation of meaningful policy that supports control technologies, cleaning
up retired extraction sites, an end to harmful and dangerous practices such.as routine flaring and
supports a just transition to sustainable energy sources will deliver the greatest long-term economic and
job creation benefits. Why should for-profit companies be able to pollute with impunity? We believe
the U.S. must work actively to reduce its greenhouse gas emissions and to transition away from an
extractive economy through public policy and strong regulation that will push private investment and
foster greater innovation. Thank you. Every step to improve the quality of markets improves the way
we all live.’

Thank You,

Graham Sinclair
472

American
usiness

SN Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas, While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Saab Lofton
473

7. American
NN Sustainable
WA Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-QAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA‘s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries,

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Lara Pearson
474

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths~especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ {tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Michelle Cortes-Harkins
475

S. American

dp A, Sustainable

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Lisa Hayles
476

American

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA's
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths~—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well- -being, | haze creates serious economic harm to the tourism and outdoor recreation
industries,

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries, The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Susan Schmidt
477

SA Sustainable
' Business
“Sz” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I'm writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Seth Eshelman _
478

SS. American

usiness

“Sa” Network |

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~— EPA-HQ-OAR-2015-0072 .

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas, While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Andrew Winston
479

SN Sustainable

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072 :

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Thomas Witt
480

=. American
SAY Business
“SE” = Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ | am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Rachael Solem
481

BS. American
S73 Business
“Sa” Network

ff

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash scot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
— lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the.tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries, The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Joe Womack
482

American
NM Sustainable
V2) Business
“SE” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Sootis a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The-current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Sandra Stewart
483

SN American
Ve SN Sustainable
N ay Business

4 Network |

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

karen stickney
484

—

iS. American
<7. Sustainable
7" Business
Ba? Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
— {am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas, While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Sam Pardue
485

iN American
, Sustainable

“ay Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
= EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—!am_calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas, While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD,-and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Clay Thompson
486

#25 American
iN Sustainable

NN

\

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
—~ EPA-HQ-OAR-2015-0072 ;

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries,

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Timon Malloy
487

JS. American
WAS > Sustainable
2) Business
“Ea” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy; which is why
~ tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries. :

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even:dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Barry Benjamin
488

=. American
SN Sustainable
(27 Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day, It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Maren Keeley
489

J American
Sd, Sustainable

“Wa” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072 .

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~—tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Stephanie Greenwald
490

DS. American
AYA) Business

WV

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous.and harming our health, environment and the economy, which is why
~ tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot. °

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

David Schreiber
491

SIN Sustainable

“Se” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent.
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and. dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

lleana vasquez
492

oN Sustainable

fy
We Business
Ne Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
om EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities, Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why.
~ tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Gina Weatherup
493

SS. American
3’ Business

("Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

L. Christina Cobb
494

American
Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
-tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts aré directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Pete Dignan
495

2 Business

Bar Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my. community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities, Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and-even dementia. -

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Charles Wolfe
496

SN American
SN Sustainable

\ < Business
way Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
poilution is extremely dangerous and harming our health, environment and the economy, which is why
~ {tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries,

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

mike kappus.
497

—

DS\. American

MS Sustainable
7777) Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HO-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~fam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas, While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy. : :

Thank You,

Ray Cooper
498

American
KN Sustainable

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environnient and the economy, which is why
~{tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Marie Mainil
499

BS. American
SA, Sustainable

2 Business
oy Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072 :

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ {am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Elizabeth Vitale
500

American

oN Sustainable
ay Business
Sa” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths~especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
-lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day; It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force.and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Richard Lawton
501

DS. American
(127° Business

=

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~{am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia. ~

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Stephen Rivard
502

y

American
N, Sustainable
2’ Business

[Ss

\

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—fam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It'is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Jackie Nufiez
503

American
SM Sustainable
Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

James Cummings
504

iS. American

f iN Sustainable
’ Business

“Sir” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Scot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—fam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national. parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Delcie Dobrovolny
505

E\ American

Sy Sustainable
usiness

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—tam calling on the Biden administration to heed the.recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Daniel OBrien
506

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Kaneisha Lewis
507

SS. American
Sustainable
' Business
“Sey” = Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities, Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot. ‘

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in-our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is.a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

David Way
508

American
SN \ Sustainable

' Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths~especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in-our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy. .

Thank You,

Chris Spychalski
509

Ae American
V/ SN Sustainable

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ {am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

William McClain
510

RN Sustainable

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value:of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Keyanna Silverman
511

American
RN Sustainable

Business.

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~—tam calling on the Biden administration to heed the recommendations of their own'scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia. ‘

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Aria McKenna
512

SN American
NN Sustainable

ay Business

Network.

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA's
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color.and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our nationalparks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates.serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current: standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Tristan Miller
513

American
BN Sustainable

' Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~!am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas, While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Laura Christina Cobb
514

S\. American
A SA, Sustainable
“Wr” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner. in my community, I’m writing today to-express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—fam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Val Muchowski
515

‘SS. American
Sustainable

“Sz” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect. public health or prevent
premature deaths—especially, in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries. ;

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy. ;

Thank You,

Dan Kirslis
516

ES. American

ee’ Network |

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Edward Savage
517

ie NIN Sustainable

‘S024 Business
NO Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
—~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~fam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Nancy Black
518

American
SM Sustainable
' Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA‘s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~fam calling on the Biden administration to heed the recommendations of their own-scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is ‘a deadly and dangerous pollutant that millions of Americans are exposed to every day, It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Mike Englert
519

American
sy Sustainable
(2 Business

Y Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities, Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~fam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Justin Green
520

SN American

ia SN Sustainable

a Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soct pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~tam calling on the Biden administration to heed the recommendations of their c own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Dr Kenneth R Pelletier
521

st Sustainable
| Business

ig Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Jerry Rivers
522

SO Sustainable
AN y Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HO-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities, Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~—lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas, While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy. :

Thank You,

Deborah Gavrin Frangquist
523

American
NNN Sustainable
27 Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths~especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries,

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. it is. linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Elric Centers
524

eS. American

SEN Sustainable
' Business.

[27 Network

Docket Nuniber: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Leslie Sheridan
525

SN American
usiness
ee? Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment.and the economy, which is why
~lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day, It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries, The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Lorraine Forte
526

iS. American
NN Sustainable

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, !’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect.public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot,

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Linda Jarmusz
527

American

, Sustainable
<2) Business

“Sb” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Ramona Duhoux
528

2 Business

be" Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities: Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. it is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Russell Donnelly
529

eS American
NIN Sustainable |
127! Business
Network .

Docket Number: Recorsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities, Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Susanne Hesse & Doug Dyer
530

ES. American
NN Sustainable
ZV) Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, i'm writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
— 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas, While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries, The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy. :

Thank You,

Barrett Walker
531

eS American
I. Sustainable
Va) Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public-health or prevent
premature deaths—especially in communities of color and historically overburdened communities, Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
-tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Dorrit Lowsen
532

CS SN American
SH Sustainable
V2) Business
“Ser Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

kelly ohara
533

WN American
“el” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas, While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Karla Kavanaugh ,
534

KON Sustainable

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~{!am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our. national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries,

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day, It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Mark Canright
535

a American
NIN Sustainable

AS Rey Business

Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072. ©

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
-1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and. are insufficient
to protect our health, the environment, and the economy.

Thank You,

Susan Peirce
536

eS. American
NN Sustainable
2’ Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths~especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Dr. Kakha NADIRADZE
537

| BB American

SIN Sustainable
Business |

i Network

‘Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—tam-calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Jason McClain
538

eS. American

NN Sustainable
17270! Business

LS

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent.
premature deaths—especially in communities of color and historically overburdened communities. Soot -
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—l|am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are-exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Cheryl Elkins
539

‘ American
I, Sustainable

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072 :

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately stash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries,

Soot is a deadly and dangérous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Stephen Wyman
540

SS. American
I. ’ Business
“Se” = Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HO-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
— {am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas, While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated. since 2012 and are insufficient
to protect our health, the environment, and the economy. ‘

Thank You,

Aaron Fumarola
541

2% Business

Ea” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities, Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~fam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

P. Alan Thiesen
542

Yay) Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths~especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia,

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

thalia lubin
543

SA Sustainable
V7) Business

Ea’ Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Seth Perlman
544

iS. American
\\ Sustainable
Vs Business

=

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is. why
—1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed'to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Bernardo Alayza Mujica
545

aS American
‘7! Business
“Slee” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~{am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot. ‘

Soot causes haze, which can severely diminish visibility and mar beautiful-vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall ;
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Leah Danger
546

S\. American
NIN Sustainable

\WESAY!' Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
— 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Liz Rubin
547

KN Sustainable

W272’ Business

Zi

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HO-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~—1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

A.L. Steiner
548

usiness

Ee” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—fam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Jesse Bennett
549

cw American

“Ser Network
Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~— EPA-HQ-OAR-2015-0072 .

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths~especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americaris are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

‘Derek Gendvil
550

SA Sustainable

2! Business

#

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Therewse Revesz
551

oN American
NN Sustainable

“Wer” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths~especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Jeffrey Scales
552

= American
Ly SN Sustainable
AN / ' Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to‘express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities, Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Brian Caneda
553

SIN Sustainable

i Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic-areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

tim brainerd
NO Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~|am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism. and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for Soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Dianna Cohen
555

American
SN Sustainable
27) Business
<7 Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

William Wallin
556

American
ON Sustainable
Ba? Network |

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HO-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA's
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why |
~1!am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Janice Brown
557

y

American
|, Sustainable

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA's
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
- 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

William Nash
558

SS. American
iA, Sustainable
' Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072 -

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
— 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Gregory Fite
559

SN American
a, Sustainable
' Business
“SE” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my-community, I’m writing today to express my disappointment with EPA's
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
— lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia,

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Rebekah Miel
560

American
RN Sustainable
“727 Business
“2” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072 ;

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths~especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia,

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Marley Finnegan
561

SS

Sa =. American
Sy Sustainable

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my. community, I'm writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
— {am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national. parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Gillie Roberts
562

BS. American

Business

ba” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—l!am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

James Dawson
563

SS American
A, Sustainable
AV) Business
ta” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries. ,

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Siham Khalid-Bloch
564

~% American

=

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans aré exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Prasad Jaladi
565

sa American
+) Sustainable
Business
Ma” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is. why
-{am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Geoffrey Mazullo
566

oN American
SH Sustainable

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ fam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day, It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Christopher Loch
567

S\. American
SA, Sustainable
(29) Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ {tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries,

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to.every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Kathryn Kelly
568

American
KN Sustainable
ay Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities: Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to. protect our health, the environment, and the economy.

Thank You,

Stephen Dorage
Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, !’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
— 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries, The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Peter Junker
570

PS. American
NINN Sustainable
Ba’ Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent.
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~|am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy. :

Thank You,

Martin Wolf
571

American
ay Sustainable
i! Business

“Se”, Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries. .

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Chad Speight
572

American
oN Sustainable
\\ X27) Business
“Sz” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~fam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the Strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Madelyn George
573

nN American

SN, Sustainable

27) Business
oy Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s —
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths~especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
— 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being; haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries, The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Steven Adams
574

American
MN Sustaina ble

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
— {am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries. ;

‘Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Anna M Lyles
575

Sustainable
2 Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries,

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia. -

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries, The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Scott Henderson
576

SS. American
i 7 Business
“Sie”, Network

=

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, ’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our heaith, environment and the economy, which is why
~ 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Monica Meng
577

American
N Sustainable

ay Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072 ;

Dear EPA Administrator Regan,

As ‘a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous-pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Taj DeHart
578

Lm American

‘S24 Business
Vee Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Marilyn Bruno
579

—

2 Sustainable

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities, Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
— {am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current. standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Emily Snyder
580

2. American
SA Sustainable
A) Business
“SI Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries, The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy. ‘

Thank You,

Kristine Waldren
581

—

ES. American
2 Business

“Siz” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Charles Lynd
582

BS. American
NIN Sustainable
\' Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
-{am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans ate exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

George Law
583

cS. American
ZV Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Jodi Hershey’
584

=. American
\\ Sustainable

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA's
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of colorand historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ {am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates.serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Mark Hayduke Grenard
585

S\ American
3) Sustainable
<2 Business
“Sil =~ Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ fam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Américans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy. .

Thank You,

Dana Weintraub
586

42S. American
V\. RN Sustainable
ay Business
We Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, !’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Karen Berger
587

BS. American
2 Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072 |

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities, Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ {am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is.a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

\

Thank You,

Ken & Susan Wiltse
588

A “~ American

i oy Sustainable
\/ Business
“SE” Network

Docket Number: Recofisideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community,.l’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

David Robinov
589

I, Sustainable
Vay) Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OQAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Rudy Arredondo
590

BS. American
‘VS Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HO-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities, Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas, While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries, The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Mary Walsh
591

SN American
SAW Sustainable
7’ Business
<i" Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities, Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries. .

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Marc Migliazzo
592

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current. standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Katherine DiMatteo
593

S\ American
IM Sustainable
O77) Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesri’t adequately slash soot pollution, protect public health or prevent
premature deaths~especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy,

Thank You,

Dulanie La Barre
594

BS. American
> Sustainable
2 Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities, Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Harvy Simkovits
595

SS. American
\, Sustainable

Way Business

ey Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths~especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation —
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Anna Sampson
596

American
CN Sustainable

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community; I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment. and the economy, which is why
—{tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic. areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Tim Wheeler
597

WAV) Business
SY Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
- 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to.every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Jarrett Cloud
598

S25. American
RN Sustainable

ay Business

“Sl” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Phil Williams
599

SS American

SIN Sustainable
' Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

Asa business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming.our health, environment and the economy, which is why
—tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel-and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other'scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Wallace Mcmullen
600

LESS American
' Business
i | 4 Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries,

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Leslie Sheridan
601

S25. American
KN Sustainable

i Ay! Business

‘Ss | Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Leah Missbach Day
602

oN American
ue Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan, .-

As a business owner in my community, I’m writing today to-express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities, Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ {am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot. ;

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy. ;

Thank You,

Ben Gordesky
603

ay Sustainable
' Business

“Se” Network .

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter

Dear EPA Administrator Regan,

Asa business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Phillip. Gioia
604

eS. American

sustainable
usiness

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Scott Hed
605

eS. American
I, Sustainable

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities, Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~}am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries,

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Robert Fingerman
606

SS. American
Sa, Sustainable
2) Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—tam calling. on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the Joss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries, The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Justin Acciavatti
607

BS. American

Ba’ Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries. ‘

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy. ;

Thank You,

Karen Malley
608

EX. American
Oo] Sustaina ble
4 Business

Be” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit.soot. :

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy. ;

Thank You,

michelle hoexum
609

Se Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072 .

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—1{am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Marley Finnegan
610

i American
usiness

‘ Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
—~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in-my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal-that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths~especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
— 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries,

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries, The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

ferris kawar
611

=. American
A, Sustainable
Y\)' Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas, While the loss of breathtaking scenery is significant and lowers. overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries,

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day, It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Zachary Dolan
612

BA. American
NIN Sustainable

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—~lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Ela Thomas
613

—

(ZV) Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~{am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall :
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day, It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You, —

Ashley Craig
614

‘\ American
IN, Sustainable
“2 Business

\

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot. ;

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries,

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Georgia Do
615

SM Sustainable
KV Business

Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072 ;

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit scot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Justin Evans
616

7 Business
“Sle” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot. :

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overail
community well-being, haze creates serious economic harm to the tourism and outdoor recreation

Soot is a deadly and.dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Jessica Caron
617

DBS. American.
ANN, Sustainable
ZV) Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent .
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~{am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Jacquelyn Crema
618

BS. American
WAZ! Business

“SE” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—lam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

michelle le
619

SS. American
NINN Sustainable

#
Nee? Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~- EPA-HQ-QAR-2015-0072 :

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries, The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Alyssa Owens
620

American
NIN Sustainable
2’ Business
Ee” Network ©

Vv,

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072 :

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Carol Atwood
621

CN American
@ Sustainable
Nie usiness
“le” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Derek Meadows
622

=. American
iN, Sustainable

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HOQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ 1am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot. .

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers. overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Hacah Goggin
623

Sy Sustainable
' Business

‘ae Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
—tam calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Sister Joan Agro
624

BS. American
Mi Sustainable

17) Business

“Sila” Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~{!am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot. ‘

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is.significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Nina Laboy
625

oN American
SIN Sustainable
Vay’ Business

Bs’ Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

You know how bad soot.is for human health -- it makes people sick, and it kills people. And it's soooo
easy to prevent! We owe it to ourselves, especially for those of us who live in communities of color and
historically overburdened communities, to get rid of soot and all the human and economic harm soot
does. Your own scientific advisory panel recognized the problem and recommended better standards.
I'm a business leader in Vermont, and tourism isa major economic driver here. The more we allow our
vistas to get obscured by soot-caused haze, the worse our economy will be.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy. The vehicles and smokestacks that emit soot
will in fact be cheaper to operate once soot production is eliminated. Come on now! Together, let’s
make America healthier, lower our health care costs, improve our air quality and outdoor recreation,
and generally make everyone happier. :

Thank You,

Bram Kleppner Middlebury, Vermont
626

‘~ American
IX, Sustainable
2’ Business
ca” Network

VN

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HOQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, 'm writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is dangerous and as it finds its way into water sources causing pollutes both water and soil
systems. Soot pollutes the air and thus our health, environment andthe economy, which is why.| am
calling on the Biden administration to heed the recommendations of its own scientific advisory panel
and to enact the strongest possible standards to limit soot pollution.

Soot also causes haze, which diminishes visibility and mars beautiful vistas in our national parks and »
other scenic areas. While the lessening of breathtaking scenery is significant and lowers overall .
community well-being, haze creates serious economic harm to the tourism and outdoor recreation ,
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy. Healthy clean air, water, and soil are the
underpinnings of life for US citizens. Without these, we perish.

Thank You,

Tim Redmond
627

= American
NM Sustainable

mM

\

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As involved members in our community, We're writing today to express our disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ we are calling on the Biden administration to heed the recommendations of their own scientific
advisory panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy. :

Thank You,

Fran Aguirre ‘ : .
628

PS. American
EN Sustainable
2! Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths~especially in communities of color and historically overburdened communities; Soot
pollution is extremely dangerous and harming our health, environment and the economy, which is why
~ {am calling on the Biden administration to heed the recommendations of their own scientific advisory
panel and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze. creates serious economic harm to the tourism and outdoor recreation
industries. My green roofs capture and sequester particulate matter from the air--I am doing my part,
and | ask you to do yours.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Jeanne Weber
629

American
ash Sustainable

Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter

Dear EPA Administrator Regan,

We need to take aggressive actions to protect our environment and to protect the health of our citizens.
Please do everything possible to reduce soot.

Thank You,

Steve Kaye
630

American
Sustainable
yi Business
Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

EPA’s inadequate proposal doesn’t adequately slash scot pollution, protect public health, or prevent
premature deaths~especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harms our health, environment and the economy. | call on the
Biden administration to follow their scientific advisory.panel and enact the strongest possible standards
to limit soot. Haze creates serious economic harm to the tourism and outdoor recreation industries.
Soot is linked to many chronic health conditions, including asthma, heart disease, COPD, and even
dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries, The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Terrence McNally
631

American

Sb, Sustainable

‘ee’ Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As a business owner and environmental justice advocate in my community, I’m writing today to express
my disappointment with EPA’s inadequate proposal that doesn’t adequately slash soot pollution,
protect public health or prevent premature deaths—especially in communities of color and historically
overburdened communities. Soot pollution is extremely dangerous and harming our health,
environment and the economy, which is why —1 am calling on the Biden administration to heed the
recommendations of their own scientific advisory panel and to enact the strongest possible standards to
limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Ona Porter
632

=. American

SH Sustainable
. Business

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
~~ EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan, .

As a business owner inmy community, Vm writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash smoke pollution, protect public health or prevent
premature deaths~especially in communities of color and historically overburdened communities.
Smoke pollution is extremely dangerous and harming our health, environment and the economy, which
is why — | am calling on the Biden administration to heed the recommendations of their own scientific
advisory panel and to enact the strongest possible standards to limit smoke pollution. Smoke causes
haze, which can severely diminish visibility and mar beautiful vistas in our national parks and other
scenic areas. While the loss of breathtaking scenery is significant and lowers overall community well-
being, haze creates serious economic harm to the tourism and outdoor recreation industries. See .
https://phys.org/news/2022-08-dangerous-combination-extreme-affected-million.html Soot is a:\deadly
and dangerous pollutant that millions of Americans are exposed to every day. It is linked to many
chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Bruce Preville
VA)! Business
Ba’ Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear. EPA Administrator Regan,

As a business owner in my community in North Carolina and a retired economist | know how important
it is for the EPA to provide adequate guardrails and guidelines for business to act in the best interest of
our communities. | am disappointed with EPA’s proposal that doesn’t adequately slash soot pollution,
protect public health or prevent premature deaths—especially in communities of color and historically
overburdened communities. Soot pollution is extremely dangerous and harming our health,
environment and the economy, which is why —! am calling on the Biden administration to heed the
recommendations of their own scientific advisory panel and to enact the strongest possible standards to
limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas, While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries. These industries are especially important to our community in western North Carolina.

Even more importantly, soot is a deadly and dangerous pollutant that millions of Americans are exposed
to every day. It is linked to many chronic health conditions, including asthma, heart disease, COPD, and
even dementia. :

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are
insufficient to protect our health, the environment, and the economy. | urge you to act providing the
guardrails to protect out communities and the guidelines for business to make choices in their and our
communities best interests.

Thank You,

Susan Kask
634

VA)’ Business
Be” Network

i

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As an academic physician specializing in respiratory medicine, I’m writing today to express my
disappointment with EPA’s inadequate proposal that doesn’t adequately slash soot pollution, protect
public health, and prevent premature deaths—especially in communities of color and historically
overburdened communities. Scientific research in recent years has strengthened the evidence that
airborne soot is hazardous to human health at lower concentrations than previously recognized, besides
its deleterious effects on the environment/biosphere generally and on the economy. | therefore urge
the Biden administration to heed the recommendations of their own scientific advisory panel and to
enact the strongest possible standards to limit pollution by soot. Aerosolized soot, measured as PM10
and-esp. as PM2.5, is an injurious pollutant that millions of Americans (and billions globally) are exposed
to every day. At the global scale particulate air pollution is among the leading causes of remediable __
excess mortality (WHO), It is linked to many chronic health conditions, including asthma, cardiovascular
disease, COPD, and even dementia.

These impacts decrease the productivity of the labor force, shorten lifespans, and reduce the value of
outdoor industries. The current standards for soot pollution haven’t been updated since 2012 and are
insufficient to protect our health, the environment, and the economy. Moreover, soot causes haze,
which can severely diminish visibility and mar beautiful vistas in our national parks and other scenic
areas, While the loss of breathtaking scenery is significant and lowers overall community well-being,
haze creates serious economic harm to the tourism and outdoor recreation industries.

Thank You,

A. Ross Hill, M.D.
635

SN American
ue ' Business
NI Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

The EPA has failed to go far enough to protect the air we breathe. Avoiding open air is not an option.
Unlike avoiding polluted water which, in emergencies, can be distributed in bottles, the air we have is
the air we breathe. So, stating the obvious, we need-the EPA to set livable standards for air pollution.
I'm very disappointed with EPA’s inadequate proposal that fails to adequately slash soot pollution,
protect public health or prevent premature deaths—especially in communities of color.and historically
overburdened communities. Soot pollution is not only extremely dangerous and harmful to our health, it
also affects the environment and the economy. For example, haze creates. serious economic harm to the
tourism and outdoor recreation industries. Haze and pollution diminish the value of open space to the
overall community they are designed to improve. Soot is a deadly and dangerous pollutant that
millions of Americans are exposed to every day. It is linked to many chronic health conditions, including
asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy. We respectfully request that the Biden
administration heeds the recommendations of its own scientific advisory panel and enacts the strongest
possible standards to limit soot. :

Thank You,

Ann Woll
YZ Business
“SEZ” = Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

This physician protests EPA’s inadequate proposal that doesn’t adequately slash soot pollution, protect
public health or prevent premature deaths~especially in communities of color and historically
overburdened communities. Soot pollution is extremely dangerous and harming our health,
environment and the economy, which is why —1 am calling on the Biden administration to heed the
recommendations of their own scientific advisory panel and to enact the strongest possible standards to
limit soot. .

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

B Dudney MD
637

American
MN Sustainable
Va) Business
“Ser Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As the Executive Director of the Coalition of Large Tribes, I’m writing today to express my
disappointment with EPA’s inadequate proposal that doesn’t adequately slash soot pollution, protect
public health or prevent premature deaths—especially in communities of color and historically
overburdened communities. Scot pollution is extremely dangerous and harming our health,
environment and the economy, which is why —! am calling. on the Biden administration to heed the
recommendations of their own scientific advisory panel and to enact the strongest possible standards to
limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions, including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven’t been updated since 2012 and are insufficient
to protect our health, the environment, and the economy.

Thank You,

Oliver Semans
638

SN American

\V' Business

LS

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HO-OAR-2015-0072 :

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate. proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths~especially in communities of color and historically overburdened communities. We
must put. credence behind the findings of science iin order to keep us all safe. Soot pollution is extremely
dangerous and harming our health, environment and the economy, which is why —1 am calling on the
Biden administration to heed the recommendations of their own scientific advisory panel and to enact
the strongest possible standards to limit soot. 7

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries.

Sootisa deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic health conditions; including asthma, heart disease, COPD, and even dementia.

These impacts are directly lowering the productivity of the labor force and lowering the value of outdoor
industries. The current standards for soot pollution haven't been updated since 2012 and are insufficient
to protect our health, the environment, and the economy. :

Thank You,

Jim Epstein
639

=. American
i, Sustainable
120i Business

NS Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter

Dear EPA Administrator Regan,

As a business owner in my community, I’m writing today to express my disappointment with EPA’s
inadequate proposal that doesn’t adequately slash soot pollution, protect public health or prevent
premature deaths—especially in communities of color and historically overburdened communities. Soot
pollution is extremely dangerous and harming our health, environment and the economy, all for the
benefit of wealthy executives and corporations for whom any regulation is anathema, no matter how
little of an impact it could have on their bottom lines. This is why | am calling on the Biden
administration to heed the recommendations of their own scientific advisory panel and to enact the
strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall
community well-being, haze creates serious economic harm to the tourism and outdoor recreation
industries, weakening our economy as a whole in favor of select well-connected companies.and
executives. Soot is a deadly and dangerous pollutant that millions of Americans are exposed to every
day. It is linked to many chronic health conditions, including asthma, heart disease, COPD, and even
dementia.

These impacts are directly lowering the productivity of the labor force - and causing long-term health
problems that will add further burdens to families and taxpayers down the road - as well as the value of
outdoor industries. The current standards for soot pollution haven’t been updated since 2012 and are
insufficient to protect our health, the environment, and the economy. It is time to bring them up to date
with the most current science.

Thank You,

Zach Bernstein
640

: SN American
aN, Sustainable

NEY Network

Docket Number: Reconsideration of the National Ambient Air Quality Standards for Particulate Matter
— EPA-HQ-OAR-2015-0072

Dear EPA Administrator Regan,

As.a former EPA employee, I’m writing today to.express my disappointment with EPA’s inadequate
proposal that doesn’t adequately slash soot pollution, protect public health or prevent premature
deaths—especially in communities of color and historically overburdened communities. Soot pollution is
extremely dangerous and harming our health, environment and the economy, which is why —!am
calling on the Biden administration to heed the recommendations of their own scientific advisory panel
and to enact the strongest possible standards to limit soot.

Soot causes haze, which can severely diminish visibility and mar beautiful vistas in our national parks
and other scenic areas. While the loss of breathtaking scenery is significant and lowers overall

community well-being, haze creates serious economic harm to the tourism and outdoor recreation

Sootisa deadly and dangerous pollutant that millions of Americans are exposed to every day. It is linked
to many chronic diseases.

Thank You,

Wendi Shafir
641

— ACC MEMBER SURVEY
American

Chemistry ee
Council impact of Rising

Regulations on Chemical
Manufacturing &
American Priorities

EMISTRY
TES
642

A Message from Chris Jahn, President s

CEO of the American Chemistry Council:
644

Chemistry Contributes to |
Supporting National Priorities

and sequestration.

62%
© of chemical manufacturers

report producing @ chemical input used

in infrastructure; They produce chemicals
and synthetic materials used in road
construction, large infrastructure projects
{i.e., bridges, dams), water treatment and
distribution, energy-efficient buildings, and
EV charging stations.
646

Growing Regulatory Burden

rden has

= number

guiations to co:

incre

ue to increase over the next year.

Now 84%

report the jevel

of regulatory burden
has increased on the
federal level

33%

report the level

of requiatory burden
has increased on the

report the level
of regulatory burden
has increased on the
state level

BER

RVEY
647

FUTURE 91%

anticipate the level
of regulatory burden
to increase on the
federal jevel

46%

anticipate the level
of regulatory burden
to increase on the
focal level

anticipate the fevel
of regulatory burden

to increase on the
state level

ACO ME
648

Impact of Regulations on National Priorities

manufacture!

Many of the that produc

prioritized by the Administ:

ory burden n

product
current and/e

al input{s} in the t

ey, this was fou

Biomanufacturing Products

Infrastructure

9% of producers reporting current and/or forthcoming requiatory burden negatively impacts ability
to competitively produce chemical input(s) in U.S.
650

Chemical Manufacturers Say:

sforthe productionoF medical
652

Regulatory Challenges and issues

turers reported the ulations

Chem

to comply w ‘@ due ta:

_ 81%

final rule absent an adequate
understanding of my business
and my compliance

: Regulatory agencies using
their legal discretion to set a

standard that is more stringent
than it should be,

Inconsistency betweer regulations
issued by different levels of
government (Le, between USA and
another country, between federal
and state regulatory agencies, etc.},

62%

Regulatory agencies enforcing
ambiguous requirements
inconsistently or inappropriately.

And companies mentioned other reasons, includine jan timelines

istent ar delayed; siow responses.to regulatory permi
regulations
aith and the

that are in
substance PMN is
and reporting burdens th
environment; and regulatior

pensive and takes too long toa
t do not reflect the rist

pased on improper ar inade
653

Big Return on Fixing Regulations

enario where existing regulatory compliance c

id saved resources would be diverted towards:

Investment in R&D,
new technologies,
and new products

Capital replacement

{operational efficiency)

Increased hiring,
expanding operations /
capacity, sustainability.
initiatives.
654

Methodology

istry Council (ACC) condu

e Americari Cn

understand how the)
participated in the survey. 38% of the

businesses” employing 550 ar iéss full-time

Fthis publication to
r neither the American

in the pre

Every effort has

lable information, H

provide the bast av

nor any of its emplo 5, or other a

gns,

2d or implie

ity, express

nfarmation or

any use, or the resuits of

s prepared by ACC's Econorr Departrnent.

bout the survey and findings may

Emily Sanchez | Director, Econamics & Data Ana
656

Americar’
Chemistry
Council
657

Environmental Protection Agency
EPA Docket Center (EPA/DC)

Mail Code 28221T

1200 Pennsylvania Ave. NW
Washington, DC 20460

Subject: Comments for National Emission Standards for Hazardous Air Pollutants (NESHAP):
Ethylene Oxide Emissions Standards for Sterilization Facilities Residual Risk and Technology Review

Docket 1D No. EPA-HO-OAR-2019-0178

Submitted: June 27, 2023

Dear EPA Staff,

The undersigned legislative members of the Texas House and Senate are concerned about the
communities in our state affected by Ethylene Oxide (EtO) sterilization facilities. We welcome the
opportunity to comment on the proposed EPA rule to curb the hazardous emissions these sterilization
plants pose to our Texas workers and neighboring families.

We understand the proposed rule is estimated to cut both fugitive and stack emissions of EtO from
these plants by as much as 80 percent when the rule is implemented. Though we appreciate this
projected goal, we would like the following measures included in the rule to help ensure the end results
of this action meet its intended outcome:

1. Require Fenceline Monitoring: Fenceline monitoring is a reliable and useful tool to understand
the amount of fugitive, controlled and uncontrolled emissions coming from commercial
sterilizers. Both the workers within the plants and the communities surrounding the facilities
need to be assured that they are protected. Fenceline monitoring is a proven method, as
evidenced in other facilities, for verifying the effectiveness of emission control equipment in
detecting fugitive emissions.

2. Inclusion of Off-site Storage Warehouses: The proposed rule covers EtO emissions from
commercial sterilizers and their on-site warehouses and other on-site storage areas. The
proposed rule, however, does not cover off-site warehouses and/or storage areas. We are
concerned that off-site warehouses, not included in the rule, could be used as a secondary
aeration area for off-gassing sterilized equipment, skirting the health-protective emission
controls and monitoring that is to be required at the primary facilities. High levels of fugitive
emissions have been discovered in off-site warehouses in other parts of the country. Many, if
not all, off-site warehouses are not regulated by the Clean Air Act and do not contain the
emissions controls systems necessary to capture residual EtO that is off-gassed from newly
sterilized equipment. Evidence suggests that off-site storage warehouses can generate
significant hazardous EtO emissions. For example, in 2019, the Georgia Environment Protection
Division issued a notice of violation to Beckon, Dickinson and Company, a medical sterilization
company, for operating an off-site warehouse in Covington without an air quality permit.*
Therefore, we request that off-site storage facilities be included in the rule.

Statement from Georgia EPD Regarding BD Notice of Violation. (2019, December 20). Environmental Protection Division.
https://epd.georgia.gov/press-rel /2019-12-20/ georgia-epd-regarding-bd-notice-violation
658

3. Shorten the Implementation and Compliance Timeline: Communities have long awaited the
development of this new EtO rule, having faced decades of hazardous and carcinogénic
pollution from these facilities. The EPA has proposed an 18-month timeline for the installation
of pollution controls once the final rule is issued. Every month these controls are not installed
poses an increased risk to plant workers and surrounding communities. We would like to
propose an expedited timeline of no more than 6 months for implementation to protect the
public's health and safety.

4. EPA must continue to require that all EtO commercial sterilizers be covered in the final rule:
We are grateful that EPA requires both major and area source commercial sterilizers to comply
with the requirements of the proposed rule. It is especially important for states like Texas, since
the Texas Commission on Environmental Quality’s (TCEQ) cancer risk estimate for EtO is far
below EPA’s. We urge EPA to keep this requirement in the final rule in order to protect the
health and safety of communities like ours.

Finally, since many of these facilities are located in underserved communities of color where English
is not spoken as a first language, we would request that multilingual information on the facilities and
surrounding risks to neighboring communities be made available.

We thank the EPA for considering our comments on this important rule to tighten the emissions
standards for EtO sterilization facilities. We look forward to seeing the finalization of this rule and
its inplementation to protect the families and communities of Texas.

Sincerely,

Texas State Senators:

Senator Carol Alvarado, District 6 Senator José Menéndez, District 26
Senator Sarah Eckhardt, District 14 Senator Judith Zaffirini, District 21

Senator Roland Gutierrez, District 19 Senator Nathan Johnson, District 16
Texas State Representatives:

659

Representative Salman Bhojani, District 92

Representative Neave Criado, District 107

Representative John Bryant, District 114

Representative Mihaela Plesa, District 70

Representative John Bucy Ill, District 136

Representative Ana-Maria Ramos, District 102

Representative Yvonne Davis, District 111

Representative Richard Raymond, District 42

Representative Jessica Gonzalez, District 104

Representative Ron Reynolds, District 27

for Row

Representative Vikki Goodwin, District 47

Representative Toni Rose, District 110

Representative Julie Johnson, District 115

Representative Chris Turner, District 101

Representative Venton Jones, District 100

Representative Gene Wu, District 137

Representative Terry Meza, District 105

Representative Erin Zwiener, District 45
660

Additional Texas State Representatives:

Representative Rafael Anchia, District 103 Representative Jarvis Johnson, District 139
661

aa
a asa Congressional
4 Research
Service

Analysis of an Estimate of the Total Costs of
Federal Regulations

name redacted
Specialist in American National Government

April 6, 2011

Congressional Research Service
R41763

CRS Report for Congress

Prepared for Members and Committees of Congress
662

Analysis of an Estimate of the Total Costs of Federal Regulations

Summary

Some policy makers have expressed an interest in measuring total regulatory costs and benefits
(e.g., the Congressional Office of Regulatory Analysis Creation and Sunset and Review Act of
2011, H.R. 214, 112" Congress), and estimates of total regulatory costs have been cited in support
of regulatory reform legislation (e.g., H-R. 10, the Regulations from the Executive In Need of
Scrutiny (REINS) Act, H.R. 10, 112" Congress). However, measuring total costs and benefits is
inherently difficult. This report examines one such study to illustrate the complexities of this type
of analysis.

A September 2010 report prepared by Nicole V. Crain and W. Mark Crain for the Office of
Advocacy within the Small Business Administration (SBA) stated that the annual cost of federal
regulations was about $1.75 trillion in 2008. This cost estimate was developed by adding together
the estimated costs of four categories or types of regulation: economic regulations (estimated at
$1.236 trillion); environmental regulations ($281 billion); tax compliance ($160 billion); and
regulations involving occupational safety and health, and homeland security ($75 billion). Some
commenters have raised questions about the validity and reliability of this estimate.

For example, Crain and Crain’s estimate for economic regulations (which comprises more than
70% of the $1.75 trillion estimate) was developed by using an index of “regulatory quality.” One
of the authors of the regulatory quality index said that Crain and Crain misinterpreted and
misused the index, resulting in an erroneous and overstated cost estimate. Other commenters have
also raised concerns about using the index to estimate regulatory costs, and about the regression
analysis that the authors used to produce the cost estimate. Crain and Crain said that they believe
they interpreted and used the regulatory quality index correctly.

Crain and Crain’s estimates for environmental, occupational safety and health, and homeland
security regulations were developed by blending together academic studies (some of which are
now more than 30 years old) with agencies’ estimates of regulatory costs that were developed
before the rules were issued (some of which are now 20 years old). Although the agency
estimates were typically presented as low-to-high ranges, Crain and Crain used only the highest
cost estimates in their report. The Office of Management and Budget has said that estimates of the
costs and benefits of regulations issued more than 10 years earlier are of “questionable
relevance.”

Crain and Crain’s estimate for the cost of tax paperwork was based on data from the Internal
Revenue Service and the Tax Foundation, but OMB data indicate that the number of hours of tax
paperwork may be much higher than Crain and Crain’s estimate. On the other hand, the authors’
assumptions regarding the cost of completing the paperwork may be too high. A threshold
question, however, is whether tax paperwork should be considered in the same category as
regulatory costs. OMB does not include tax paperwork in its annual reports to Congress.

Crain and Crain said they did not provide estimates of the benefits of regulations, even when the
information was readily available, because the SBA Office of Advocacy did not ask them to do
so. OMB’s reports to Congress have generally indicated that regulatory benefits exceed costs.
Crain and Crain said their report was not meant to be a decision-making tool for lawmakers or
federal regulatory agencies to use in choosing the “right” level of regulation. This report will not
be updated.

Congressional Research Service
665

Analysis of an Estimate of the Total Costs of Federal Regulations

Introduction

Regulation, like taxing and spending, is a basic function of government. Each year, federal
agencies issue between 3,000 and 4,000 final rules on topics ranging from the timing of bridge
openings to the permissible levels of arsenic and other contaminants in drinking water. Unlike
taxing and spending, however, the costs that nonfederal entities pay to comply with federal
regulations are not accounted for in the federal budget process. Some policy makers have
expressed an interest in measuring total regulatory costs and benefits. For example, the.
Congressional Office of Regulatory Analysis Creation and Sunset and Review Act of 2011 (ELR.
214, 112" Congress) would require the newly created office to issue “an annual report including
estimates of the total costs and benefits of all existing Federal regulations.” As discussed later in
this report, for nearly 14 years, Congress has required the Office of Management and Budget
(OMB) to prepare a report each year on the aggregate costs and benefits of federal rules. '

However, measuring total regulatory costs and benefits is inherently difficult, For example,
researchers must determine the baseline for measurement (i.¢., what effects would have occurred
in the absence of the regulation) and aggregating the results of studies conducted years earlier
with different methodologies and quality can be highly problematic. Some observers, including
OMB, currently doubt whether an accurate measure of total regulatory costs and benefits is
possible.

The Crain and Crain Report

In September 2010, the Office of Advocacy within the Small Business Administration (SBA)
released a report prepared for the office by Nicole V. Crain and W. Mark Crain entitled “The
Impact of Regulatory Costs on Small Firms.”” Among other things, the report stated that the
annual cost of federal regulations in 2008 was about $1.75 trillion. The September 2010 report
was the fourth such report prepared for the SBA Office of Advocacy in the previous 15 years:

¢ In 1995, Thomas D. Hopkins estimated annual federal regulatory costs that year
to be between $416 billion and $668 billion.’

* In 2001, W. Mark Crain and Hopkins estimated the annual cost of regulations in
the year 2000 at $843 billion.’

' ‘The current requirement is in Section 624 of the Treasury and General Government Appropriations Act, 2001, (31
U.S.C. § 1105 note), sometimes referred to as the “Regulatory Right-to-Know Act.”

* See http://www. sba. gow/sites/default/files/rs37 ltot.pdf to view a copy of this report. Hereafter, this report is referred
to as “Crain and Crain.” In addition to estimating the annual cost of federal regulations, the report also provided
information indicating that regulatory costs fall particularly hard on small businesses, The report was developed under
a contract with the SBA-Office of Advocacy (contract number SBAHQ-08-M0466). Although the report cover states
that it “contains information and analysis that was reviewed and edited by officials of the Office. of Advocacy,” it also
says that the “final conclusions of the report do not necessarily reflect the views of the Office of Advocacy.”

* Thomas D. Hopkins, “Profiles in Regulatory Costs,” available at http://www.sba. gow/sites/default/files/files/

* W. Mark Crain and Thomas D. Hopkins, “The Impact of Regulatory Costs on Small Firms,” available at
http./Awww.sba.gow/sites/default/files/files/rs207tot.pdf. For an analysis of this estimate, see CRS Report RL32339,
Federal Regulations: Efforts to Estimate Total Costs and Benefits of Rules, by (name. redacted).

Congressional Research Service 1
666

Analysis of an Estimate of the Total Costs of Federal Regulations

-* Tn 2005, W. Mark Crain estimated annual regulatory costs in 2004 at about $1.1
trillion.”

The $1.75 trillion estimate of regulatory costs has been widely quoted in the press,° by witnesses
at congressional hearings,’ and by Members of Congress,* and it has been cited as evidence of the
need for regulatory reform legislation and congressional oversight actions.’ Other observers,
however, have criticized the estimate, saying that it overstates the total cost of federal

This report examines how Crain and Crain developed the $1.75 trillion estimate of federal

regulatory costs in 2008. It also compares the $1.75 trillion estimate for 2008 with the $1.1
trillion estimate for 2004, and with OMB’s estimates of regulatory costs in 2008.

How Crain and Crain Developed the $1.75 Trillion
Estimate of Regulatory Costs

Crain and Crain developed their $1.75 trillion estimate of total regulatory costs by adding
together cost estimates for each of four categories or types of regulation: economic regulations
($1.236 trillion); environmental regulations ($281 billion); tax compliance ($160 billion); and

* W. Mark Crain, “The Impact of Regulatory Costs on Small Firms,” available at http://www. sba, gov/sites/default/files/
files/rs264tot.pdf.

* See, for example, Chad Moutrey, “To cure the economy, fix the business environment,” Washington Post, January 10,
2011, available at http://www. washingtonpost.cony wp-dyn/content/article/201 1/01/07/AR201 101070568 1.html;
“Obama's reformer disguise; Accountability is the solution to government red tape,”. Washington Times, January 26,
2011, p. B2; and Mark Tapscott, “Washington is the Reason the Economy Is Not Growing,” The Examiner, December
2, 2010, p. 39.

’ See, for example, testimony of Thomas M. Sullivan, before the House Committee on Education and Workforce,
Subcommittee on Workforce Protections, February 15, 2011, available at http://edworkforce. house. gov/UploadedFiles/
02.15.11 _sullivan.pdf; and testimony of Karen Harned, before the House Committee on the Judiciary, Subcommittee
on Courts, Commercial and Administrative Law, February 10, 2011, available at http://judiciary.house. gov/hearings/

* See, for example, Senator Dan Coats, “Coats Says Excessive Regulation is Hindering Private Sector Job Growth,”
Press Statement in support of S, 358, February 16, 2011, available at http://coats.senate.gov/newsroom/press/release/?
id*F6E06668-FE12-460E-9D04-4ED61 1EAB111; Opening of Rep ative Sam Graves, Chairman,
House Committee on Small Business, February 16, 2011, available at http://smbiz.house.gov/UploadedFiles/
2011.02.16 State_of_SmBiz_Opening.pdf, and a letter to President Barack Obama by four House committee chairmen,
available at http://geoffdavis. house. gov/UploadedFiles/POTUS_Letter_03101 1 pdf.

° See, for example, http://www. geoffdavis, house. gov/Legislation/reins.htm, and http://www.geoffdavis.house.gov/
News/DocumentSingle.aspx ?DocumentID=208463, in support of the “Regulations from the Executive In Need of
Scrutiny (REINS) Act,” H.R. 10 in the 112" Congress; http://snowe. senate. gov/public/index.cfin/pressreleases?
ContentRecord_id=49fe0 | bb-b475-4ffl -b9e I -7ea6edaS0b7e&Content Type_id=ae7a6475-a01 f4da5S~aa4-
support of the Small Business Regulatory Freedom Act of 2011, S. 474 in the 112° Congress; and H.Rept. 112-6;
“Directing Certain Standing Committees to Inventory and Review Existing, Pending, and Proposed Regulations and
Orders from Agencies of the Federal Government, Particularly With Respect to Their Effect on Jobs and Economic
Growth,” Report to accompany H.Res. 72, February 8, 2011.

® Carl Bialik, “The Numbers Guy: Small Business Regulatory ‘Burden’ Is Tough to Quantify,” Wail Street Journal,
January 29, 2011, p. A2; and Sidney A. Shapiro, Ruth Ruttenberg, and James Goodwin, “Setting the Record Straight:
The Crain and Crain Report on Regulatory Costs,” Center for Progressive Reform White Paper #1103, February 2011,
available at http://www.progressivereform.org/articles/SBA_Regulatory_Costs_Analysis_1103.pdf (“CPR report”).

Congressional Research Service 2
667

Analysis of an Estimate of the Total Costs of Federal Regulations

regulations involving occupational safety and health, and homeland security ($75 billion). As
Figure 1 below illustrates, the estimated cost of economic regulations was more than 70% of the
authors’ estimate of total regulatory costs.

Figure 1. Economic Regulations Were More Than 70% of Crain and Crain's Estimate
of Total Regulatory Costs

Occupational
Safety/Health
and Homeland
Security , 4.3%

Tax
Compliance,
9.1%

Environmental,
16.1%

Economic,
70.6%

Source: CRS, based on data from Crain and Crain, September 2010.

Note: Due to rounding, the individual segments total 100.1%.

Economic Regulations

According to the Crain and Crain report, “[e]conomic regulations include a wide range of
restrictions and incentives that affect the way businesses operate—what products and services
they produce, how and when they produce them, and how products and services are priced and
marketed to consumers.”"! They said such regulations affect both domestic and international
business operations, and include quotas and tariffs on foreign imports that “limit competition
from outside the United States, restrict production and employment, raise prices, and generally
curtail U.S. economic activities.”!? To develop an estimate of the cost of economic regulations,
Crain and Crain used a Worldwide Governance Index (WGI) of “regulatory quality” that was
developed by Aart Kraay and Massimo Mastruzzi of the World Bank, and Daniel Kaufmann of

"' Crain and Crain, p. 17.

Congressional Research Service 3
668

Analysis of an Estimate of the Total Costs of Federal Regulations

the Brookings Institution.'* According to Crain and Crain, the WGI regulatory quality index
“measures perceptions of the ability of governments to formulate and implement sound policies
and regulations that permit and promote private sector development.”"* Crain and Crain said the
index was calibrated to range between -2.5 and +2.5, and that +2.5 represented “the minimal
amount of regulation.”'* In 2008, the WGI regulatory quality index score for the United States
was +1.579.

Crain and Crain used regression analysis’® in an effort to determine the impact of changes in the
regulatory quality index on real Gross Domestic Product (GDP) per capita, holding constant four
other variables that they said the literature suggests explain differences in economic development
across countries and over time: country population, primary education as a share of the eligible
population, foreign trade as a share of GDP, and fixed broadband subscribers per 100 people.
Using this approach, Crain and Crain concluded that a one-unit change in the WGI regulatory
quality index (e.g., a change from +1.5 to +2.5 on the scale) represented a 9.4% change in real
GDP per capita, Because the regulatory quality index for the United States in 2008 was +1.579,
Crain and Crain said that the 0.921 difference between that value and the +2.5 maximum
represented an 8.7% reduction in GDP (0.094 times 0.921) because of economic regulations.
Because GDP in the United States was about $14.2 trillion in 2008, Crain and Crain concluded
that the types of economic regulations included in the regulatory quality index reduced real GDP
per capita in the United States by about $1.236 trillion ($14.2 trillion times 0.087).

Composition of the Regulatory Quality Index

According to Kaufmann, Kraay, and Mastruzzi, the WGI index of regulatory quality for the
United States in 2008 was determined by aggregating six expert-based measures and two surveys,
each of which was scored on a 0 to 1 scale.” The six expert-based measures, their scores, and the
particular factors considered in each measure were as follows:

¢ Economist Intelligence Unit (scored at 0.70), a commercial business information
provider headquartered in London, England. The score is based on its experts’
judgment of 16 factors, including “protectionism in the country negatively affects
the conduct of business,” “access to capital markets (foreign and domestic) is
easily available,” “real corporate taxes are non distortionary,” “labor regulations
hinder business activities,” and “easy to start a business.”

'3 iy addition to “regulatory quality,” the WGI indices include five other governance indicators: “voice and
accountability,” “political stability and absence of violence,” “government effectiveness,” “rule of law,” and “control of
corruption.” The WGI methodology is described in Kaufmann, Kraay and Mastruzzi (2010). “The Worldwide
Governance Indicators: Methodology and Analytical Issues” World Bank Policy Research Working Paper No. 5430,
http://papers.ssrn.com/sol3/papers.cfm?abstract_id=1682130.

4 Crain and Crain, p. 19.

'S Wid. p. 24.

6 Regression analysis is used to understand how the value of a dependent variable (e.g., real GDP per capita) changes
when one of the independent variables is varied (e.g., the index of regulatory quality), while the other independent
variables (e.g., country population) are held fixed.

"7 Here, and elsewhere in the Crain and Crain report, cost estimates are provided for 2008 in 2009 dollars. It is unclear
why Crain and Crain used 2009 dollars to present cost estimates for 2008.

8 See http://info. worldbank.org/governance/wgi/pdf/rq.pdf. Documentation for each individual source is available at
http://info. worldbank. org/governance/wgi/sources. htm.

Congressional Research Service 4
669

Analysis of an Estimate of the Total Costs of Federal Regulations

Global Insight Business Conditions and Risk Indicators (scored at 0.94). Global
Insight is a commercial business information provider headquartered in Boston,
Massachusetts. The score is based on its experts’ assessment of two factors: (1)
“tax effectiveness,” defined as “how efficient the country’s tax collection system
is”; and (2) “legislation,” defined as “whether the necessary business laws are in
place, and whether there any outstanding gaps.”

Global Insight Global Risk Service (scored at 0.95). Global Risk Service is a
commercial business information provider headquartered in Boston,
Massachusetts. The score is based on its experts’ judgment of five factors: (1)
“export regulation,” (2) “import regulation,” (3) “other business regulation,” (4)
“nonresident business ownership restrictions,” and (5) “nonresident equity
ownership restrictions.” ;

Heritage Foundation Index of Economic Freedom (scored at 0.73). The Heritage
Foundation is described by the WGI index as a “nongovernmental research and
educational institute headquartered in Washington, United States, advocating
conservative public policies.” The index score is based on its experts’ judgment
of two factors: (1) “foreign investment” and “banking/finance.”

Institutional Profiles Database (scored at 0.89), which is provided by the French
government’s Ministry of the Economy. The score is based on its experts’
judgment of four factors: (1) “ease of starting a business,” (2) “administered
prices and market prices,” (3) “competition: productive sector: ease of market
entry for new firms,” and (4) “competition between businesses: competition
regulation arrangements.”

Political Risk Services International Country Risk Guide (scored at 1.00).
Political Risk Services is a commercial business information provider
headquartered in Syracuse, New York. The score is based on their experts’
judgment of one factor entitled “investment profile,” summarizing the investment
environment.

The two surveys used to develop the regulatory quality index, their values, and the particular
factors considered in each survey were as follows: .

Institute for Management and Development World Competitiveness Yearbook
(scored at 0.50). The Institute for Management Development is an educational
and research organization headquartered in Lausanne, Switzerland. The score is
based on a survey of business people working in the United States, who are asked
to comment on the same 16 factors used by the Economist Intelligence Unit
mentioned above (e.g., “protectionism in the country negatively affects the
conduct of business,” “access to capital markets (foreign and domestic) is easily
available,” “real corporate taxes are non distortionary,” “labor regulations hinder
business activities,” and “easy to start a business”).

World Economic Forum Global Competitiveness Report (scored at 0.62). The
World Economic Forum is an international organization based in Switzerland. Its
survey asked domestic and foreign-owned firms their views regarding seven
statements: (1) “administrative regulations are burdensome,” (2) “tax system is
distortionary,” (3) “import barriers/cost of tariffs as obstacle to growth,” (4)
“competition in local market is limited,” (5) “it is easy to start company,” (6)

Congressional Research Service 5
670

Analysis of an Estimate of the Total Costs of Federal Regulations

“anti-monopoly policy is lax and ineffective,” and (7) “environmental regulations
hurt competitiveness.”

Some observers have questioned whether WGI indices, such as the regulatory quality index,
“measure what they purport to measure,””” and the authors of the WGI have responded to those
concerns.” Crain and Crain noted in their report that the World Bank Development Research
Group published a detailed description of how the WGI indices were developed,” and noted that
the WG] indices were correlated with an index of economic regulations developed by the
Organization for Economic Cooperation and Development (OECD) that Crain had used in his
2005 study of federal regulatory costs.” Crain and Crain said they used the WGI regulatory |
quality index in their 2010 study because it covered more countries for a longer period of time
than the OECD index, and because it used a variety of sources and dimensions.

In a “Frequently Asked Questions” page on the World Bank’s website, the WGI authors indicated
that indices such as the regulatory quality index are “useful as a first tool for broad cross-country
comparisons and for evaluating broad trends over time,” but cautioned that they are “often too
blunt a tool to be useful in formulating specific governance reforms in particular country
contexts.” They went on to say that such reforms “need to be informed by much more detailed
and country-specific diagnostic data that can identify the relevant constraints on governance in
particular country circumstances.”

Comments Regarding the Estimate of the Cost of Economic Regulations

The’ validity and accuracy of Crain and Crain’s estimate of the cost of economic regulations
depends on at least two factors: (1) whether the WGI index of “regulatory quality” can be used as
part of a formula to measure the cost of economic regulations, and (2) whether the authors
interpreted the regulatory quality index in the way it was intended. Several commenters on the
Crain and Crain study have addressed one or both of these issues.

Comments from Aart Kraay of the World Bank

On January 27, 2011, Aart Kraay, a lead economist in the Development and Research Group at
the World Bank, and one of the authors of the WGI regulatory quality index, contacted Crain and
Crain by e-mail and provided his views on their use of the index in their September 2010 report
on regulatory costs.”" Kraay said that although “in principle an exercise like this could make

See, for example, M.A, Thomas, “What Do the Worldwide Governance Indicators Measure? European Journal of
Develapment Research, vol, 22 (2010), pp. 31-54.

? Daniel Kauffman, Aart Kraay, and Massimo Mastruzzi, “Response to ‘What Do the Worldwide Governance
Indicators Measure?’” European Journal of Develapment Research, vol. 22 (2010), pp. 55-58.

*\ Daniel Kaufman, Aart Kraay, and Massimo Mastruzzi, “Governance Matters VII: Aggregate and Individual
Governance Indicators 1996 ~ 2008,” World Bank Development Research Group, Macroeconomics and Growth Team,
Policy Research Working Paper 4978, June 2009.

” See G. Nicoletti, Scarpetta, and O. Boylaud, “Summary Indicators of Product Market Regulation and Employment
Protection Legislation for the Purpose of International Comparisons,” OECD Economics Department Working Paper
No, 226 (2000).

3 World Bank, “World Governance Indicators: Frequently Asked Questions,” available at http://info. worldbank.org/

* Kraay provided CRS with a copy of his January 27, 2011, e-mail to Crain and Crain on March 4, 2011.

Congressional Research Service 6
671

Analysis of an Estimate of the Total Costs of Federal Regulations

sense,” he said that he believed there were two “basic problems with how you use our data.” First,
he said that although Crain and Crain interpreted higher values of regulatory quality as “less
stringent regulations,” “[t]his isn't a good characterization of what the [regulatory quality, or RQ]
index measures—rather RQ seeks to measure perceptions of the overall quality of the regulatory
environment, which is very different from simply measuring whether it is ‘stringent’ or not.”
Kraay noted that the United States came in at about the 90" percentile of all countries in the
world, and that countries like Finland and Sweden rank ahead of the United States on regulatory
quality. “So by this standard,” he said, “it is hard to say that the RQ measure ‘rewards’
deregulation.” He also said that he and the other WGI authors had “indicated throughout that the
WGI indicators are not literally true and have non-trivial margins of error, indicating that there is
of course imprecision in how countries are ranked.”

The second major issue that Kraay noted was that Crain and Crain “may be misinterpreting the
units. of the WGI” by comparing the United States’ score of +1.579 to +2.5---what the authors
referred to in the report as “the minimal amount of regulation,”*° and what Nicole V. Crain had
referred to in a Wall Street Journal article as a “conceptual regulatory environment.””’ In his e-
mail to the authors, Kraay said the following:

You claim that 2.5 is the “best possible” score on the WGI. But this isn’t really correct as the
WGI are measured in units which don’t have a fixed upper or lower boundary (technically
the units are those of a standard normal random variable). It would make a lot more sense for
you to compare the US score on RQ with that of a country whose regulatory environment
you prefer, and then use that difference in score to calibrate the costs of regulations. So for
example the highest numbers we see on WGI-RQ in 2009 are around 1.8 for countries like
Singapore, followed closely by Denmark (!), The US comes in at around 1.4. So a more
relevant comparison would be between the US and Denmark, rather than between the US and.
2.5. This of course would mean that your estimated costs of regulation would be a lot
smaller, since the distance between the US and Denmark is much smaller than the distance
between the US and 2.5."

(Kraay told CRS that the WGI authors periodically make minor revisions to WGI data for
previous years, thus explaining the difference between the +1.579 regulatory quality index that
Crain and Crain cited, and the “around 1.4” value that he noted in his e-mail to Crain and
Crain.) Using the same 2008 data that Crain and Crain used in their study, the nation with the
highest regulatory quality index was Ireland, with a value of +1.915.*° Subtracting the United
States’ regulatory index value from that of Ireland yields a difference of 0.336 (1.915 minus
1.579), As noted earlier, Crain and Crain used regression analysis to conclude that a one-unit
change in the regulatory quality index represented a 9.4% change in real GDP per capita. If this

5 In his comments to Crain and Crain, Kraay continued by saying that “one should not make a big deal of the fact that
Sweden and Finland come in a bit ahead of the US, as the difference is not statistically significant (the margins of error
overlap). But this does give you a good indication that WGI-RQ is not just measuring ‘less regulation’ as you seem to
interpret it.”

6 Crain and Crain, p. 24.

”’ Carl Bialik, “The Numbers Guy: Small Business Regulatory ‘Burden’ Is Tough to Quantify,” Wall Street Journal,
January 29, 2011, p. A2.

*8 E-mail from Aart Kraay to Crain and Crain, January 27, 2011.

* E-mail to the author from Aart Kraay, World Bank, March 4, 2011.

*°-To view the data, see http:/Avww-wds. worldbank.org/external/default/WDSContentServer/TW3P/1B/2009/06/29/
000158349_20090629095443/Rendered/PDF/WPS4978 pdf. Two other jurisdictions had higher scores than Ireland in
2008, but they are technically not countries (Hong Kong, at 1.998, and Singapore, at 1.918).

Congressional Research Service 7
672

Analysis of an Estimate of the Total Costs of Federal Regulations

measure is correct, the 0.336 difference between the Ireland and United States regulatory quality
indices suggests a 3.16% reduction in GDP (0.094 times 0.336 equals 0.0316) in the United States
compared with Ireland, the country with the least “stringent” regulatory climate. Therefore, the
monetary “cost” of this GDP reduction would be about $448 billion (0.0316 times $14.2 trillion
GDP in 2008), or about $788 billion less than the $1.236 trillion that Crain and Crain calculated.
However, all of the above calculations assume that higher values on the regulatory quality index
reflect “less stringent regulations,” which Kraay indicated it does not.

Kraay also told CRS that he had concerns about the quality of Crain and Crain's regression
analysis. He said “The problem is simply that high scores on regulatory quality are correlated
with a lot of other good policies and institutions which also matter for GDP per capita. And so it
is hard to sort out how much of the correlation between RQ and GDP per capita is due to the
regulatory environment per se, and how much is due to other stuff.’?! He also said that “unless
one can perfectly control for all these other factors (which is nearly impossible), the econometric
estimates [that Crain and Crain] provide will reflect not just the effects of regulation on output,
but also of all those other policies that are correlated with regulation.”

When contacted by CRS for comment, Crain and Crain said that they understood Kraay’s
conceptual argument that the regulatory quality index might not reflect changes in the
“stringency” of regulation, but they said that “the empirical evidence indicates that it does in
practice.” They said the index captures the extent of regulation from a variety of stakeholders’
perceptions, and noted the nature of the questions used to construct the index (e.g., “How
problematic are labor regulations for the growth of your business?” and “How problematic are
customs and trade regulations for the growth of your business?”). Crain and Crain also said they
did not compare the United States to another country (e.g., Denmark) because to estimate the cost
of regulations to small and large businesses (what they contracted with SBA to do), they needed
to estimate the total cost of all regulations. They also said they do not believe that they
misinterpreted the WGI measure because the documentation provided by the WGI authors
indicates that the index values range from about -2,5 to +2.5, and they selected +2.5 as the “best
approximation of the regulatory environment that we were trying to capture in our estimate.”

Other Commenters

Before publishing the Crain and Crain report, the SBA Office of Advocacy had the study peer
reviewed by two economists—Bob Litan of the Kauffman Foundation,” and Richard Williams of
the Mercatus Center™ at George Mason University.”* Litan’s complete comments were “I looked
it over and it’s terrific. Nothing to add.” Williams’s comments were more extensive. Overall, he
said that the study was a “great project,” and he hoped his comments would make it stronger. In
relation to the estimate of the costs of economic regulations, he said the use of the index of

3 E-mail to the author from Aart Kraay, World Bank, March 4, 2011.

32 E-mail to the author from Nicole V. Crain and W. Mark Crain, March 7, 2011.

38 ‘The Ewing Marion Kauffman Foundation is described on its website as one of the largest foundations devoted to

The Mercatus Center is described on its website as the world’s premier university source for market-oriented ideas.
See http://mercatus.org/.

3 According to a March 7, 2011, e-mail to the author from Radwan Saade of SBA’s Office of Advocacy, the study was
sent to the two peer reviewers “that identified as credible researchers and contributors to the discussion on regulatory
costs.” He said other researchers were contacted but were ilable to serve as peer reviewers.

Congressional Research Service 8
673

Analysis of an Estimate of the Total Costs of Federal Regulations

regulatory quality was an “innovative idea,” but said he was “concerned that the index may not
measure what the authors say it measures, and even if it does, it may overstate the costs of
regulation when used in conjunction with the other measures.”** Among other things, he said that
the study “might over-estimate the total costs of regulation because the effect of the Regulatory
Quality Index on GDP may also capture some or all of the effects of environmental, workplace,
security, and tax regulations.” On the other hand, Williams also said that “there are reasons to
believe that [the index] may underestimate costs.”*’ He said some of the problems “could perhaps
be solved simply with a better and more careful explanation of what the Regulatory Quality Index
really measures. To guard against over-estimating costs, however, the authors would either need
to control for the effects of other types of regulation on GDP, or refrain from adding some or all
of the costs that are estimated via other methods.”

In February 2011, the Center for Progressive Reform (CPR) issued a report criticizing the Crain
and Crain study, and has requested that SBA’s Office of Advocacy withdraw its sponsorship of
the report.** In relation to the estimate of economic regulatory costs, CPR said (among other
things) that (1) the WGI authors did not intend the regulatory quality index to be a proxy measure
for regulatory burden, or as a tool for critiquing a particular country’s regulatory stringency; (2)
the lack of a clear definition of “economic regulations” raises the possibility that it includes other
types of regulatory costs, which could lead to double counting; (3) the regression analysis used in
the report assumes a simplistic relationship between regulatory “stringency” and GDP; and (4)
the report gives the false impression that the index of regulatory quality in the United States is
low, even though the United States ranked 11" out of more than 200 countries.”

CRS Analysis of Crain and Crain’s Linear Regression

The Crain and Crain report analyzed data for 25 OECD countries in order to assess the effect of
economic regulation on GDP per capita, a common measure of the standard of living.”'

*6 Comments of Richard Williams, Mercatus Center, George Mason University, available at http://www.sba.gov/sites/
default/files/files/ThelmpactofFederalRegulatoryCostsonSmallFirmsPRF Y2010,pdf.

37 Williams said “You can start with the fundamental idea of opportunity costs. Resources that are devoted to
complying with regulations are not used to produce GDP that responds to normal market forces (demand). Both
activities, complying with regulations and normal market activities add to GDP. What has been estimated here is the
difference between the two, GDP with resources that would have been devoted to normal market forces minus GDP
with resources devoted to complying with regulation. That difference is, I think, one component of the cost of
regulation. However, that may leave, (if 1 am thinking about this correctly) the cost of complying with regulation that is
picked up by GDP. That is, a person can produce 10 widgets that comply with regulation and 15 widgets if employed
normally by the market, and this model would estimate the costs of the regulation at 5 widgets (the difference in GDP).
But that doesn’t count the original 10 widgets of expenditure that adds to GDP and is also a cost and must be weighed
against the benefits.”

38 Sidney A. Shapiro, Ruth Ruttenberg, and James Goodwin, “Setting the Record Straight: The Crain and Crain Report
on Regulatory Costs,” February 2011, available at http://www.progressivereform.org/articles/
SBA_Regulatory_Costs_Analysis_1103.pdf. See http://www.progressivereform.org/articles/SBA_Letter_020811.pdf
for a copy of the letter requesting that SBA’s Office of Ad y withdraw its spc hip of the Crain and Crain
report, In a March 11, 2011, letter to CPR, the Chief Counsel of SBA’s Office of Advocacy said that he disagreed with
CPR’s assessment, and stood behind the findings of the Crain and Crain report.

® Wid, pp. 4-6.

“ This section of the report was written by (name redacted), Analyst in Economic Policy, Congressional Research
Service.

*! The OECD has 34 member states. Chile, Slovenia, and Israel joined in 2010, and Estonia is in the final stages of
formal accession. Some historical data for those new entrants is unavailable. See OECD website (http://www.oecd.org)
for details.

Congressional Research Service 9
674

Analysis of an Estimate of the Total Costs of Federal Regulations

Economists generally believe that a country’s standard of living is affected by a variety of factors,
including the availability of (1) land and natural resources, (2) labor and human capital, (3)
capital and infrastructure, (4) the level of technology and sophistication of business practices, and
(5) opportunities to trade with other countries.” Most economists also believe that government
interventions in the economy (e.g., through taxes, spending, and regulation) can affect a country’s
standard of living.”

As noted previously in this report, Crain and Crain used linear regression analysis to examine the
relationship between GDP per capita and the regulatory quality index, controlling for the effects
of four other independent variables: country population; foreign trade as a share of GDP; primary
education as a share of the eligible population; and fixed broadband subscribers per 100 people.“
These four control variables may not capture all of the factors that affect GDP per capita, and
other measures of those factors may be more appropriate. For example, “fixed broadband
subscribers per 100 people” may or may not capture all aspects of capital investment, and may
also partially reflect other factors (e.g., the state of information technology investment, population
density, and per capita income levels).*° The Crain and Crain report did not discuss how the
authors selected the control variables used in their analysis.

Crain and Crain also used an estimation strategy that appears non-standard. Like many
researchers, Crain and Crain analyze data for several countries over multiple years, known as a
cross-country panel data set. Linear regressions on panel data often include country-specific
control variables (fixed effects) to take into account national idiosyncrasies that do not vary over
time and year-specific control variables to account for shocks that affected all countries in the
sample in a given year.” Crain and Crain, however, reported that year-specific control variables
that were estimated to be statistically insignificant in an unreported first-stage regression were
then omitted from the reported second-stage regression results.‘’ The statistical properties of this
two-stage estimation strategy, which appears to be novel, has apparently not been explored in
peer-reviewed journals.

CRS asked Crain and Crain to provide us with a copy of the data that they used in their study, but
the authors did not do so. In an effort to assess the sensitivity of their results, CRS ran a linear
regression using similar, but somewhat different, data and methods.* The results indicated that
the regulatory quality index had no discernable independent effect on GDP per capita, suggesting

2 Rudiger Dornbusch, Stanley Fischer, and Richard Startz, Macroeconomics (10" ed.), (New York: McGraw-Hill,
2008), ch. 1 and 2.

* Randall G. Holcombe, Public Finance, (Minneapolis: West, 1996).

“ For details on the linear regression model and its statistical properties, see Peter Kennedy, A Guide to Econometrics
(4" Edition), (Cambridge, Massachusetts: MIT Press, 1998), ch. 3, “The Classical Linear Regression Model.”

“* In another study, Crain and Crain used a measure of equipment investment in an article that example determinants of
GDP per capita for a sample of 99 countries, See Nicole V. Crain and W. Mark Crain, “Terrorized Economies,” Public
Choice, vol. 128, pp.317-349.

4 Badi Baltagi, Econometric Analysis of Panel Data 4" ed.), (New York: Wiley, 2008). If certain technical conditions
hold, this approach can generate estimates with desirable statistical properties. See William H. Greene, Econometric
Analysis (New York: Prentice Hall, 2003), ch. 13, “Models for Panel Data.”

*7 See notes to Table 2 in Crain and Crain (2010).

“ The primary education variable was replaced with two demographic variables: the proportion of the population under
age 14, and the proportion of the population over age 65. The data were for 30 OECD countries for the same time
period as the Crain and Crain study (2002 ~ 2008). The analysis used a standard fixed-effects panel estimator with year
dummy variables.

Congressional Research Service 10
675

Analysis of an Estimate of the Total Costs of Federal Regulations

that the analysis is highly sensitive to the choice of control Variables and measures. Appendix of
this report discusses this sensitivity analysis and the results in greater detail.

While most economists believe that economic regulation, like other forms of government
intervention, can affect a country’s standard of living, those effects may be too subtle for a seven-
year cross-country panel to pick up. A country’s regulatory environment may evolve slowly, and
may interact with social and political conditions, other instruments of public policy.such as
taxation. Understanding the relationship between a measure of regulatory quality and GDP per
capita (or other measures of economic well being) may require more focused. empirical tools.

Environmental Regulations

Crain and Crain said they developed their cost estimates for environmental regulations by
following the same basic approach as used by OMB in its annual reports to Congress. For
environmental regulations issued through the first quarter of the year 2000, the authors used
OMB’s:estimate of environmental costs from its 2001 report to Congress” (which was drawn in
part from a study by Robert W. Hahn and John A. Hird),”° which the authors converted into 2001
dollars.*' For environmental regulations issued from April 1999 through September 2001, Crain
and Crain used the estimate of the cost of major environmental rules from OMB’s 2002 report.”
For each subsequent fiscal year (October through September), the authors used estimates of the
cost of major environmental rules from the subsequent OMB report. By adding together all of
these cost estimates and converting the estimates from 2001 dollars to 2009 dollars, the authors
concluded that environmental regulations cost between $175 billion and $280 billion in 2009.
However, to develop the cumulative cost of all regulations, Crain and Crain used only the $280
billion estimate. The authors said their use of only the upper-end estimate “reflects a judgment
that cost estimates are absent for important environmental regulations and that government
agencies tend to be conservative in estimating regulatory costs.”

The data that Crain and Crain used to estimate the costs of environmental rules represent a mix of
academic estimates of the cost of all rules prior to 1988, agency estimates of the costs of all rules
issued between 1987 and the first quarter of 2000, and agency estimates of the costs of major
rules (e.g., those with a $100 million or more annual impact on the economy) issued from April

© See http://www. whitehouse. gow/sites/default/ files/omb/assets/omb/inforeg/costbenefitreport pdf for OMB’s 2001
report,

* Robert W. Hahn and John A. Hird, “The Costs and Benefits of Regulation: Review and Synthesis,” Yale Journal of
Regulation, vol. 8 (1991), pp. 233-278. Hahn and Hird provided estimates for all rules issued prior to 1988. The
estimate for niles issued from 1987 through the first quarter of 2000 were from agencies’ estimates of all rules.

5! In jts 2001 report, OMB estimated environmental costs as of the first quarter-of 2000 at between $96 billion and $170
billion, in 1996 dollars. In 2001 dollars, Crain and Crain said the costs were between $108.359 billion and $191.887
billion,

* See http://www. whitel gov/sites/default/files/omb/assets/omb/inforeg/2002_report_to. congress.pdf for OMB’s
2002 report. In this and all subsequent reports, OMB’s estimates were in 2001 dollars. As used in this report, the term
“major rule” includes all rules meeting the definition in the Congressional Review Act (5 U.S.C. § 804(2) (e.g;, an
annual. effect on the economy of $100 million or more), For a discussion of “major rules,” see CRS Report R41651,
REINS Act: Number and Types of “Major Rules” in Recent Years, by (name redacted) and (name redacted).

> Crain and Crain, p. 27. In a March 7, 2011, e-mail to the author, Crain and Crain noted that the OMB data do not
include regulations whose costs are expected to be below $100 million, or costs that are not monetized. Therefore, they
said, using the upper bound is an attempt to correct for this omission in a systemic and reasonable way. They also said
that agency cost estimates are unlikely to include costs associated with negotiated enforcement.

Congressional Research Service 1
676

Analysis of an Estimate of the Total Costs of Federal Regulations

1999 through September 2008. Therefore, the unit of analysis is not the same for all of the years
(i-e., all rules prior to the year 2000 versus major rules starting in April 1999), and the
methodologies differ (i.e., academic studies prior to 1988, and agencies’ ex ante estimates of
regulatory costs after 1988). In its 2000 report to Congress, OMB said that summarizing the total
costs and benefits of regulations by adding together diverse sets of individual studies was an
“inherently flawed approach” because the studies vary in quality and methodology, use differing
assumptions, and seldom analyze the interaction effects among tens of thousands of regulations.™

Also, the time periods covered by the cost estimates that Crain and Crain used overlap in some
years, raising the possibility of double counting. For example, both the Hahn and Hird estimate
and the agency estimates cover rules that were issued in calendar year 1987. In addition, the
baseline estimates of rules issued through the first quarter of 2000 overlap with the estimates for
the period April 1, 1999, to September 30, 2001 (ie., both cover the period April 1, 1999, through
March 31, 2000).

In two of the one-year periods covered by the Crain and Crain analysis, the authors appear to
have incorrectly recorded the information on environmental regulatory costs from the OMB
reports:

© For the period October 2002 through September 2003, the authors said that
OMB’s estimate was $335 million (in 2001 dollars). Actually, OMB reported
those costs as $360 million (in 2001 dollars).*

¢ For the period October 2003 through September 2004, the authors said that
OMB’s estimate was $3,840 million to $4,073 million (in 2001 dollars). Actually,
OMB reported those costs as $3,060 million to $3,211 million (in 2001 dollars).

Also, Crain and Crain did not report any of OMB’s estimates of the benefits of environmental
regulations. As discussed later in this report, the authors indicated that regulatory benefits were
not included because they researched the topic as required by the Office of Advocacy.*’ Table 1
below shows both the estimated costs and estimated benefits of environmental rules from OMB’s
reports. Overall and in eight of the nine time periods covered by the table, the average estimated
benefits were higher than the average estimated costs. In six of the nine time periods covered by
the table, the lowest estimated benefits were higher than the highest estimated costs. The highest
estimated benefits were lower than the lowest estimated costs in only one of the time periods
(October 1, 2002, to September 30, 2003).

*4 See http://www. whiteh gov/sites/default/files/omb/: /omb/inforeg/2000fedreg-report.pdf, p. 15.

58 See httpy/www. whitehouse. gov/sites/default/files/omb/assets/omb/inforeg/2004_cb_final.pdf, p. 7, Table 1.

% See http://www. whitehouse. gov/sites/default/files/omb/assets/omb/inforeg/2005_cb/final_2005_cb_report.pdf, Table
1-3. The $3,840 million to $4,073 million cost estimate in this report is for rules issued by the Departments of Health
and Human Services and Transportation, and the Environmental Protection Agency.

57 E-mail to the author from Nicole V. Crain and W. Mark Crain, March 7, 2011.

Congressional Research Service 12
677

Analysis of an Estimate of the Total Costs of Federal Regulations

Table |. Estimates of Costs and Benefits of Environmental Rules in

OMB Reports to Congress
Years Rules Were Estimated Costs Estimated Benefits
Issued (millions of 2001$) (millions of 2001$) Source

Through 03/3 1/2000 $108,359 to $191,887 $109,490 to $1,817,280 OMB, 2001, Table 2
04/01/1999 to $11,380 to $12,812 $25,338 to $56,141
09/30/2001 OMB, 2002, Table 7
10/01/2001 to $192 $1,250 to $4,818
09/30/2002 OMB, 2003, Table |
10/0 1/2002 to $360 $204 to $355
09/30/2003 OMB, 2004, Table |
10/01/2003 to $3,060 to $3,211 $10,935 to $100,703
09/30/2004 OMB, 2005, Table 1-3
10/0 1/2004 to $2,609 to $3,373 $14,512 to $161,708
09/30/2005 OMB, 2006, Table 1-3
10/01/2005 to $2,720 to $2,965 $5,113 to $42,109
09/30/2006 OMB, 2007, Table 1-3
10/0 1/2006 to $7,475 to $7,584 $21,143 to $170,391
09/30/2007 OMB, 2008, Table 1-3
10/01/2007 to $7,591 to $8,780 $7,475 to $37,810
09/30/2008 OMB, 2008, Table 1-3
Total $143,746 to $228,274 $195,460 to $2,391,315 OMB, 200! to 2008

Source: OMB’s annual reports on the costs and benefits of regulations, available at http://www.whitehouse.gov/
omb/inforeg_regpol_reports_congress/.

Notes: The estimates of rules issued “Through 03/31/2000” includes all rules. All of the other time periods
include only major rules.

Comments Regarding the Estimate of the Cost of Environmental Regulations

Crain and Crain said their report “assumes that OMB’s coverage of environmental regulations has
been relatively complete.” Peer reviewer Richard Williams’s only comment about the estimate
of environmental regulatory cost was that this statement should be noted as an assumption.

As noted earlier, Crain and Crain said they used only OMB’s upper estimate of environmental
costs because they believed cost estimates were absent for some important environmental
regulations, and “government agencies tend to be conservative in estimating regulatory costs.
The authors stated in a footnote that several regulatory experts have drawn a similar conclusion
about OMB environmental cost estimates, but also noted that “considerable debate continues.”
Crain and Crain cited studies indicating that government agencies systematically overestimate
benefits and underestimate costs, but also cited one study by Winston Harrington and others that
reportedly concluded that overestimation of unit costs occurs about as often as underestimation.”

9989

58 Crain and Crain, p. 25.

5 Crain and Crain, p. 27.

© Ibid.

§ Ibid, footnote 27. Actually, the Harrington study concluded that agencies’ estimates of direct costs appeared to be too
(continued...)

Congressional Research Service 13
678

Analysis of an Estimate of the Total Costs of Federal Regulations

In its analysis of the Crain and Crain report, the Center for Progressive Reform said that agencies’
estimates of environmental costs tend to be too high, reflecting estimates provided to them by
industry, whom CPR said have an incentive to overstate costs. CPR also said that industry cost
estimates (and therefore the agency estimates) do not take into account technological innovations
that reduce the cost of compliance. To support its position on this issue, CPR cited four studies
indicating that agencies’ initial cost estimates tended to be too high. CPR also questioned Crain
and Crain’s use of the Hahn and Hird study to estimate the cost of environmental regulations prior
to 1988, noting that the study was more than 20 years old, synthesized other estimates developed
by a small group of economists, and some of those studies used data that are now more than 30
years old.

In responding to comments on one of its reports to Congress on the costs and benefits of
regulations, OMB noted the “theory that agency estimates, upon which many but not all of our
estimates are based, systematically understate costs and overstate benefits because agency self-
interest lies in regulation.” OMB went on to say the following:

Although this view of agency behavior enjoys widespread support among academics as a
theoretical matter, there is little documentation available to support it—perhaps because
there are several potentially offsetting factors. For example, much of the data that agencies
use to make their estimates of costs comes from the regulated entities who generally have the
opposite incentives—namely, they will likely overstate costs to help convince decision
makers not to issue the regulation. Also, as noted in our report, competitive firms over time
frequently find more cost-effective ways, including new technologies, to comply with
regulations than had been envisioned ex ante. Some commenters pointed to a set of case
studies that is about to be published to support this contention. On the other hand, there is a
large body of literature that shows that agencies tend to overestimate the benefits of their
programs because, over time, technological progress—in communications to energy
exploration { to infectious disease—has reduced the long run expected benefits of earlier
regulations.”

Tax Compliance

To estimate the costs associated with complying with federal tax paperwork, Crain and Crain said
they compiled data from the Internal Revenue Service (IRS), and in some cases the Tax
Foundation,” on the amount of time required to complete each type of tax form, and the number
of filings per form. The authors concluded that businesses, individuals, and nonprofits devoted
about 4.3 billion burden hours to completing tax paperwork in 2008 (about 2.28 billion burden
hours for business and about 2.02 billion burden hours for individuals and nonprofits). To

(...continued)

high in 12 rules, and too low in 6 rules. The authors’ Lusi ig per-unit ak costs only applied to
EPA and OSHA regulations. See Winston Harrington, et al., “On the J pesinkoe of Regulatory Cost Estimates,”
available at http://www.rff.org/documents/RFF-DP-99-18. pdf.

® Sidney A. Shapiro, Ruth Ruttenberg, and James Goodwin, “Setting the Record Straight: The Crain and Crain Report
on Regulatory Costs,” p. 7.

§} Office of Management and Budget, “Appendix: S -y of Public C a
http://www. whitehouse. gov/omb/inforeg_appendix.

“ The Tax Foundation is a nonpartisan tax research group based in Washington, D.C. For more information, see
http://www. taxfoundation.org/about/. Crain and Crain said they used information from the Tax Foundation’s 2005
report, but did not provide a citation for that report.

ilable at

Congressional Research Service 14
679

Analysis of an Estimate of the Total Costs of Federal Regulations

monetize that burden, Crain and Crain estimated the cost of completing business paperwork at
$49.77 per hour for businesses (which they said was the average hourly rate for “human resources
professionals” in 2009 from the Bureau of Labor Statistics website) and $31.53 per hour for
individuals and nonprofits (which they said was the average hourly rate for “accountants and
auditors” in 2009), for a total cost of about $159.6 billion.

Crain and Crain did not indicate in their report how they “compiled” data from the IRS website
and the Tax Foundation to arrive at the estimated 4.3 billion hours of tax paperwork in 2008.
According to the Information Collection Budget that OMB develops annually, the government-
wide paperwork burden in FY2008 was about 9.71 billion burden hours, of which the Department
of the Treasury accounted for about 7.78 billion burden hours.® Although the Information
Collection Budget did not separately identify the number of burden hours for the IRS, in May
2009, the IRS represented about 77.8% of the government-wide estimate, and about 99.5% of the
Treasury estimate. If those same ratios applied in 2008, IRS paperwork would have been about
7.5 billion burden hours—about 3.2 billion hours higher than in the Crain and Crain report.

Certain aspects of how Crain and Crain monetized IRS burden hours are also unclear. For
example, it is unclear why the authors assumed that “human resources professionals” would be
completing all business tax paperwork, that all individuals and nonprofits would have their
returns prepared by “accountants and auditors,” or where on the “Bureau of Labor Statistics
website” the hourly rates for human resources professionals ($49.77 per hour) and accountants
and auditors ($31.53) were derived. According to the Bureau of Labor Statistics’ Occupational
Employment Statistics, in May 2009, {ax preparers received an average salary of $17.34 per hour
(median salary was $14.45 per hour).*’ Even if one assumed that total compensation (including
benefits and overhead) was one-third higher, the average compensation for tax preparers would
still be just over $23 per hour ($17.34 times 1.33). Using this figure for all tax compliance may
balance out those businesses and individuals who prepare their returns themselves and those who
use more expensive preparers.” Therefore, multiplying 7.5 billion burden hours times $23 per
hour yields a total cost of about $172.5 billion—about $12.9 billion higher than the Crain and
Crain estimate.

A threshold issue, however, is whether tax paperwork should be included in estimates of
regulatory costs at all. OMB does not include tax paperwork in its annual reports to Congress on
the costs and benefits of federal regulations. In one of the first of those reports, OMB said that
“filling out tax forms is not the result of ‘regulations’ but rather of the tax code itself, with most
regulations merely providing interpretations and clarifications of tax law. »® Also, in testimony
before the House Committee on Government Reform in July 2003, John D. Graham,
administrator of the Office of Information and Regulatory Affairs (OIRA) within OMB, said the
following:

§ Office of Management and Budget, information Collection Budget: 2009 (reporting on FY2008), available at

& See CRS Report R40636, Paperwork Reduction Act (PRA): OMB and Agency Responsibilities and Burden
Estimates, by (name redacted) and (name redacted).

§7 See http://www.bls.gov/oes/current/oes 132082.htm for these data.

§ For example, BLS data indicated that accountants and auditors were paid an average of $32.42 per hour in May
2009. See http://www. bls. gov/oes/current/oes 13201 1.htm.

® Office of Management and Budget, Report to Congress on the Costs and Benefits of Federal Regulations, Septernb
30, 1997, available at http://www. whitehouse. gov/omb/inforeg_rcongress/.

Congressional Research Service 15
680

Analysis of an Estimate of the Total Costs of Federal Regulations

Toa greater extent than for other agencies and programs, IRS paperwork burden is driven by
a statute (the Tax Code), and in particular the complexities of the Code. To ensure taxpayer
compliance with our tax laws, IRS must collect a tremendous amount of information. This
task is complicated by a massive, complex Tax Code that is subject to continuous revision.
In the 15 years following the 1986 overhaul of the Code, Congress passed 84 tax laws, These
laws required IRS to create and/or revise reporting and recordkeeping requirements, which in
turn increased taxpayer burden. The Internal Revenue Service also had to make several
changes to the 1040 schedules to implement the Economic Growth and Tax Relief
Reconciliation Act of 2001. These statutorily driven revisions increased the burden on
taxpayers by 47 million hours. Moreover, there are other factors totally outside the control of
IRS—most notably increases in the number of tax filings due to economic and population
growth over the years—that increase the aggregate IRS burden hours but not—and this is
important—the average burden on individual taxpayers.”°

Occupational Safety and Health and Homeland Security
Regulations

Because the “economic regulations” category included many types of workplace regulations,
Crain and Crain said that their final category of regulatory costs included only workplace
regulations that deal with safety and health, primarily those issued by the Occupational Safety
and Health Administration (OSHA) within the Department of Labor, as well as regulations related
to homeland security. To estimate the cost of occupational safety and health regulations prior to
2001 (estimated at more than $64.3 billion in 2009 dollars), the authors used information from a
2005 study by Joseph M. Johnson that reportedly synthesized and evaluated other studies of
workplace regulations.” Crain and Crain said they then added data from OMB’s 2009 report to
Congress on regulatory costs and benefits on (1) 2001 to 2008 occupational safety and health
regulatory costs (estimated at $471 million in 2009 dollars), and (2) all homeland security costs
through 2008 (estimated at about $10.4 billion in 2009 dollars). Adding these elements together,
the authors concluded that the total cost for occupational safety and health and homeland security
regulations in 2008 was about $75.2 billion.

Crain and Crain said they obtained the estimate for occupational safety and health regulatory
costs between 2001 and 2008 from Table 1-2 in OMB’s 2009 report to Congress. That table
reports the estimated costs and benefits of major federal rules within selected programs from
October 1, 1998, through September 30, 2008. One of the programs was labeled “Occupational
Safety and Health Administration,” with the costs associated with four rules estimated at between
$362 million and $389 million (in 2001 dollars). Several of those years (October 1998 through
December 2000) appear to overlap with estimates provided in Johnson’s study of costs prior to
2001, raising the issue of possible double counting.” Also, converting the OMB estimate to 2009
dollars yields a range of $440 million to $471 million. Therefore, although the authors did not
explicitly say so, it appears that Crain and Crain only used the upper-end of OMB’s estimated
cost range for these regulations (as they did for environmental regulations).

” See http://www.whiteh gov/omb/legislative_testimony_graham_030722_graham/ for a copy of this testimony.

7 Cited by Crain and Crain as Joseph M. Johnson, “A Review and Synthesis of the Cost of Workplace Regulations, in
Cross-Border Human Resources, Labor International: Netherlands, 2005, pp. 433-467.

® although Crain and Crain said (in Table 5 on p. 30 of their report) that they only used rules issued between 2001 and
2008, the 2009 OMB report does not identify when the four Occupational Safety and Health Administration rules were
issued. Also, conversion of OMB’s upper-end estimate for all four rules ($389 million in 2001 dollars) into 2009
dollars yields an estimate of $471 million—the same figure used in Crain and Crain’s report.

Congressional Research Service 16
681

Analysis of an Estimate of the Total Costs of Federal Regulations

Crain and Crain said they obtained their estimate for homeland security costs from page 18 of
OMB’s 2009 report. There, OMB reported that since the Department of Homeland Security was
created, “agencies have finalized 17 major homeland security regulations that impose a total
annual cost on the economy of between $4.2 billion to $8.6 billion. Converting these estimated
costs in 2001 dollars to 2009 dollars yields a range of $5.1 billion to $10.4 billion. Therefore,
although they did not say so in their report, it appears that Crain and Crain again only used
OMB’s upper-end of the estimated cost range. As noted earlier in this report, the authors said that
their use of the upper-end of OMB’s estimates for environmental rules reflected a judgment that
cost estimates were absent for important regulations and that government agencies tend to be
conservative in estimating regulatory costs.” On the other hand, OMB has said that there is little
evidence that agencies’ cost estimates are too conservative.”

The Center for Progressive Reform’s analysis of the Crain and Crain report stated that the cost
estimates that the authors used for occupational safety and health costs (both the Joseph M.
Johnson study and the agency estimates of costs before the rules are published) likely overstate
true compliance costs because they are based on information provided by regulated industries.
CPR also said that the Johnson study inflates OSHA’s original cost estimates by multiplying them
by 5.5, which was reportedly done to take into account non-major rules for which costs were not
estimated, and for fines imposed for violations of OSHA standards. CPR said it saw no
justification for counting such fines as “regulatory costs.” “Under this logic,” CPR said, “mass
lawbreaking raises regulatory costs, enabling regulatory opponents to argue that we need to
reduce regulations because of these regulatory costs.””

Comparison of Crain and Crain’s 2008 Estimate to
Crain’s 2004 Estimate

As noted previously and as shown below in Table 2, in 2005, W. Mark Crain estimated total
federal regulatory costs in 2004 at about $1.11 trillion. In 2010, Crain and Crain estimated those
costs in 2008 at about $1.75 trillion—an increase of about $639 billion (57.4%) in four years.
Some of this increase is due to inflation,”° but the authors said that the main reason for the
increase was a change in the methodology used in developing their estimate of the cost of
economic regulations.” As Table 2 below indicates, were it not for the increase in the cost

® Crain and Crain, p. 27. In a March 7, 2011, e-mail to the author, Crain and Crain noted that the OMB data do not
include regulations whose costs are expected to be below $100 million, or costs that are not monetized. Therefore, they
said, using the upper bound is an attempt to correct for this omission in a systemic and reasonable way. They also said
that agency cost estimates are unlikely to include costs associated with negotiated enforcement.

4 Office of Management and Budget, “Appendix: S ¥ of Public Cc ” available at
> CPR, p. 9.

76 Crain and Crain said that the $1.1 trillion estimate of regulatory costs in 2004 would be $1.26 trillion in 2009 dollars.

” Crain and Crain, p. 20, The authors said that the 2005 study used an index of economic regulations developed by the
Organization for Economic Cooperation and Development (OECD), supplemented by information from the
International Trade Commission and other sources. Crain and Crain said they used the World Bank index of regulatory
quality because it was a more comprehensive index of economic regulations. Had the 2005 study used the methodology
used in the 2010 study, the authors said that the total cost would have been $1.7 trillion, an increase of $43 billion
between 2004 and 2008 after adjusting for inflation.

Congressional Research Service 17
682

Analysis of an Estimate of the Total Costs of Federal Regulations

estimate for economic regulations, the total estimated cost of the three other types of regulations
would have decreased by about $6 billion between 2004 and 2008.

Table 2. Changes in Estimates of the Costs of Federal Regulations: 2004 to 2008

Type of Regulation 2004 2008 Increase/Decrease (%)
Economic $591 billion $1,236 billion $645 billion increase

Environmental $221 billion $281 billion $60 billion increase

Workplace $106 billion $75 billion $31 billion decrease
(-29.2%)

Tax Compliance $195 billion $160 billion $35 billion decrease
(-17.9%)

Total $1,113 billion $1,752 billion $639 billion increase

Source: The 2004 data are from Crain (2005), and the 2008 data are from Crain and Crain (2010).

Notes: In Crain and Crain's 2010 report, “workplace” regulations were termed “occupational safety and health,
and homeland security” regulations.

Comparison of Crain and Crain’s 2008 Estimate to
OMB’s Estimates

For nearly 15 years, Congress has required OMB to submit annual reports on the costs and
benefits of federal regulations. The first such requirement was in Section 645 of the Treasury,
Postal Service and General Government Appropriations Act, 1997 (P.L. 104-208), which required
the director of OMB to submit a report by September 30, 1997, that provided (among other
things) “estimates of the total annual costs and benefits of federal regulatory programs, including
quantitative and nonquantitative measures of regulatory costs and benefits.” Similar requirements
were contained in other appropriations bills in subsequent years.

In 2001, Section 624 of the Treasury and General Government Appropriations Act, 2001, (31
U.S.C. § 1105 note), sometimes known as the “Regulatory Right-to-Know Act,” put in place a
permanent requirement for an OMB report on regulatory costs and benefits. Specifically, it
requires OMB to prepare and submit with the President’s budget an “accounting statement and
associated report” containing an estimate of the total costs and benefits (including quantifiable
and nonquantifiable effects) of federal rules and paperwork, to the extent feasible, (1) in the
aggregate, (2) by agency and agency program, and (3) by major rule. The accounting statement is
also required to contain an analysis of the impacts of federal regulation on state, local, and tribal
governments, small businesses, wages, and economic growth.

OMB’s Early Estimates of Total Regulatory Costs and Benefits

For the first several years, OMB provided estimates of total regulatory costs and benefits, and
those estimates (particularly the benefits estimates) varied substantially from year to year.

Congressional Research Service 18
683

Analysis of an Estimate of the Total Costs of Federal Regulations

e Inits 1997 report, OMB estimated total federal regulatory costs in 1997. at $279
billion, and estimated the benefits of federal regulations at $298 billion.”

e In its 1998 report, OMB estimated federal regulatory costs at between $170
billion and $230 billion (in 1996 dollars as of 1998), and estimated regulatory
benefits at between $260 billion and $3.5 trillion.” The dramatic increase in the
benefits estimate (by a factor of 12) was almost entirely due to the inclusion of an
Environmental Protection Agency (EPA) estimate of the benefits associated with
the Clean Air Act. Many observers had serious questions regarding the use of
this EPA estimate, and EPA itself said it had only a small probability of being
correct. ‘

¢ In its 2000 and 2001 reports, OMB estimated the cost of all social regulations at
between $146 billion and $229 billion (in 1996 dollars as of 1999), and estimated
benefits at between $254 billion and nearly $1.8 trillion. The nearly 50% drop
in the upper-bound benefits estimate (from $3.5 trillion to $1.8 trillion) was
primarily caused by a significant drop in the previously mentioned EPA estimate
of the benefits of the Clean Air Act (from $3.2 trillion to $1.45 trillion).

Each year, OMB presented its aggregate cost and benefit estimates with strong caveats. For
example, in its first report in 1997, OMB said “it is extremely difficult, if not impossible, to
estimate the actual total costs and benefits of all existing Federal regulations with any degree of
precision.”*! The next year OMB said “there is not yet a professional consensus on methods that
would permit a complete, consistent accounting of total costs and benefits of Federal
regulation.”®” Some of the methodological problems that OMB pointed out in these and other
reports included the following:

e The baseline for measurement is often not clear (i.e., what costs and benefits
would have occurred in the absence of the regulation). Regulatory requirements
sometimes become standard business practice (e.g., requirements to remove lead
from gasoline or to put air bags in automobiles), so cost or benefit reductions
would be unlikely to occur if the rules were eliminated entirely.

¢ It is difficult to attribute costs or benefits to federal regulations as opposed to
state or local rules, voluntary standards organizations, insurance requirements, or
the tort system.

e Technological change can make previous estimates of benefits and costs
extremely inaccurate.

e Aggregating the results of different studies is highly problematic, as the studies
vary in the quality, methodology, and types of regulatory impacts they include.

78 See http:/Awww.whitel gov/omb/inforeg_rcongress/ for a copy of this report.

® See http://www. whitehouse. gov/sites/default/files/omb/assets/omb/inforeg/costbenefitreport] 998.pdf, Table 3.

% See http://www. whitehouse. gov/sites/default/files/omb/assets/omb/inforeg/costbenefitreport.pdf, Table 2.

3! See http:/www.whiteh gov/omb/inforeg_chap2.

®2 See http://www.whitehouse. gov/sites/default/files/omb /omb/inforeg/costbenefitreport!998.pdf, p. 1.

% Specifically, in its 1997 report, OMB said “studies that have attempted tot tote up the total costs and benefits of
Federal regulations have basically added together a diverse set of individual studies. Unfortunately, these individual
studies vary in quality, methodology, and type of regulatory costs included. Thus we have an apples and oranges
problem, or, more aptly, an apples, oranges, kiwis, grapefruit, etc., problem.” See http://www.whitehouse. gov/omb/
(continued...)

Congressional Research Service . 19
684

Analysis of an Estimate of the Total Costs of Federal Regulations

e It is unclear which rules should be included in any tabulation of regulatory costs
and benefits (e.g., “transfer” regulations such as crop subsidy payments).

In developing its estimates of total regulatory costs, OMB did not include “transfer” rules (which
OMB said were about $140 billion in costs and benefits in 1997) because it considered them to be
payments that reflect a redistribution of wealth rather than social costs to society as a whole.
OMB also excluded the costs associated with filling out tax paperwork (which OMB estimated
were about $140 billion in 1997) because it did not consider filling out income tax forms
“regulations” in the traditional sense. Neither did it include estimates for rules published after
1987 for which agencies did not conduct cost-benefit analyses (e.g., rules with less than a $100
million impact on the economy).

OMB’s Reports Since 2001

OMB’s “Regulatory Right-to-Know Act” reports since 2001 have differed from the office’s
previous reports in that they have not presented cost or benefit estimates for all rules in existence.
Instead, OMB has presented information for all regulations that it reviewed within a particular
time-frame that (1) had costs or benefits of at least $100 million annually and (2) the costs and
benefits had been monetized by either the rulemaking agency or OMB. Specifically:

© OMB’s report for 2002 presented information on the costs and benefits of all
regulations meeting those criteria that it reviewed for a six-and-one-half year
period from April 1, 1995, to September 30, 2001. OMB said the total cost of
those rules was about $50 billion to $53 billion (in 2001 dollars), and the benefits
ranged from $48 billion to $101 billion.”

e In its 2003 report, OMB provided estimates of the costs and benefits of 107
regulations meeting the above criteria that it reviewed during the 10-year period
from October 1992 through September 2002. OMB estimated that the total costs
of these rules ranged from nearly $37 billion to nearly $43 billion (in 2001
dollars), with benefits ranging from $146 billion to $230 billion. OMB noted
that four rules issued by EPA accounted for a substantial fraction of the aggregate
benefits for all 107 rules.

Each report since 2003 has provided information for rules meeting the above criteria during the

previous 10 years. In its 2002 report, OMB said its decision to present data for only certain rules
during a limited time-frame was driven by the inconsistent and increasingly aged nature of many
of the studies used to develop aggregate estimates. OMB went on to say that “we do not believe
that the estimates of the costs and benefits of regulations issued over ten years ago are reliable or

(...continued)

inforeg_chap2. :

% Office of Management and Budget, Office of Information and Regulatory Affairs, Stimulating Smarter Regulation:
2002 Report to Congress on the Costs and Benefits of Regulations and Unfunded Mandates on State, Local, and Tribal
Entities, 2002, available at http://www.whiteh gov/sites/defaulv/files/omb/: /omb/inforeg/

85 Office of Management and Budget, Office of Information and Regulatory Affairs, Informing Regulatory Decisions:
2003 Report to Congress on the Costs and Benefits of Federal Regulations and Unfunded Mandates on State, Local,
and Tribal Entities, 2003, available at http://www. whitehouse. gov/sites/default/files/omb/assets/omb/inforeg/
2003_cost-ben_final_rpt.pdf.

Congressional Research Service 20
685

Analysis of an Estimate of the Total Costs of Federal Regulations

very useful for informing current policy decisions.”® Therefore, OMB said that “in keeping with
the spirit of OMB’s new information-quality guidelines, we have decided not to reproduce the
aggregate estimates that were contained in Appendix C of the draft report.”*’ The report went on
to say that the total costs and benefits of all federal rules then in effect “could easily be a factor
of ten or more larger.” In its 2003 report, OMB said that estimates prepared for rules adopted
prior to the 10-year period “are of questionable relevance now.”

This point was elaborated by John D. Graham, former administrator of OIRA, in testimony before
the House Committee on Government Reform in July 2003:

The fact that attempts to estimate the aggregate costs of regulations have been made in the
past, such as the Crain and Hopkins estimate of $843 billion..., is not an indication that such
estimates are appropriate or accurate enough for regulatory accounting. Although the Crain
and Hopkins estimate is the best available for its purpose, it is a rough indicator of regulatory
activity, best viewed as an overall measure of the magnitude of the overall impact of
regulatory activity on the macro economy. The estimate, which was produced in 2001 under
contract for the Office of Advocacy of the Small Business Administration, is based on a
previous estimate by Hopkins done in 1995, which itself was based on summary estimates
done in 1991 and earlier, as far back as the 1970s. The underlying studies were mainly done
by academics using a variety of techniques, some peer reviewed and some not. Most
importantly, they were based on data collected ten, twenty, and even thirty years ago. Much
has changed in those years and those estimates may no longer be sufficiently accurate or
appropriate for an official accounting statement. Moreover, the cost estimates used in these
aggregate estimates combine diverse types of regulations, including financial,
communications, and environmental, some of which impose real costs and others that cause
mainly transfers of income from one group to another. Information by agency and by
program is spotty and benefit information is nonexistent. These estimates might not pass
OMB’s information quality guidelines. In particular, many of the studies they relied upon for
these aggregate estimates are not sufficiently transparent about the data and methods to
facilitate the reproducibility of the information by qualified third parties. That is why we
have opted in the most recent Reports to Congress to report just the costs and benefits of
major regulations prepared by agencies and reviewed by OMB over the last ten years.®

Later that year, testifying on the Paperwork and Regulatory Improvements Act of 2004 (H.R.
2432, 108" Congress), Graham said that requiring agencies to submit annual estimates of the cost
and benefits of all their rules, and mandating preparation of a complete inventory of the costs and
benefits of all federal rules and paperwork requirements, was “not workable.”

*© See http://www. whitehouse. gov/sites/default/files/omb/assets/omb/inforeg/2002_report_to_congress.pdf, p. 40.

* tbid., p. 41, Section 515 of the Treasury and General Government Appropriations Act for Fiscal Year 2001, generally
known as the “Data Quality Act” or the “Information Quality Act,” amended the Paperwork Reduction Act and
directed OMB to issue gover -wide guidelines that “provide policy and procedural guidance to Federal agencies
for ensuring and maximizing the quality, objectivity, utility, and integrity of information (including statistical
information) disseminated by Federal agencies.”

8 See http://www.whitehouse. gov/sites/default/files/omb/assets/omb/inforeg/2003_cost-ben_final_rpt.pdf, p. 7. In its
2010 report to Congress, OMB continues to say that estimates that are more than 10 years old are of “questionable
relevance.” See http://www. whitehouse. gov/sites/default/files/omb/legislative/reports/2010_Benefit_Cost_Report.pdf,

® Testimony of John D. Graham before the House Committee on Government Reform, July 22, 2003, available at
http://www. whitehouse. gov/omb/legislative_testimony_graham_030722_graham.

® “Chief of OMB Regulatory Review Opposes Ose Bill on Regulatory Accounting, Budgeting,” BNA Daily Report for
Executives, July 23, 2003, p. A-43.

Congressional Research Service 21
686

Analysis of an Estimate of the Total Costs of Federal Regulations

OMB’s 2009 Report to Congress

OMB’s 2009 report to Congress provided estimates of the total annual benefits and costs of 98
regulations reviewed by OMB during the 10-year period from October 1, 1998, to September 30,
2008. The 98 rules were those that (1) were estimated to generate benefits or costs of
approximately $100 million in any one year; and (2) a substantial portion of the benefits and costs
were quantified and monetized by the agency or, in some cases, monetized by OMB. As Table 3
below shows, OMB said that the estimated costs of these rules ranged from nearly $51 billion to
nearly $60 billion, and the benefits were estimated to be between about $126 billion and about
$663 billion (in 2001 dollars). Because the estimates were provided for only 98 rules meeting the
above criteria, and because not all benefits and costs for even those rules could be assessed, OMB
noted that the estimates were “not a complete accounting of all of the benefits and costs of all
regulations issued during this period.””

Table 3. Estimates of the Total Benefits and Costs of Major Rules by Agency: October
1, 1998 - September 30, 2008

{in millions of 2001 dollars)

Agency Number of Rules Benefits Costs
Department of 6 $906 - $1,315 $1,014-$1,353
Agriculture
Department of i 633 ~ 786 349 - 589
Education
Department of Energy 6 4,954 - 5,391 3,067 ~ 3,118
Department of Health 18 20,522 - 32,426 3,879 ~ 4,387
and Human Services
Department of ' 20-29 13~99
Homeland Security
Department of Housing | 190 150
and Urban Development
Department of Justice ! 275 108-118
Department of Labor 6 481 ~ 1605 320 347
Department of 18 11,256 — 19,098 5,218 ~ 8,968
Transportation
Environmental 40 87,042 — 601,469 36,853 — 40,851
Protection Agency
Total 98 126,277 ~ 662,584 50,973 + 59,978

Source: OMB’s 2009 Report to Congress, Table I-1.

As in its previous reports, OMB said it presented information only for a 10-year period because
“pre-regulation estimates prepared for rules adopted more than ten years ago are of questionable
relevance today.”"? OMB also said the following:

°! OMB’s 2009 report to Congress, p. 9.

Congressional Research Service 22
687

Analysis of an Estimate of the Total Costs of Federal Regulations

Aggregating benefit and cost estimates of individual regulations—to the extent they can be
combined—provides significant insight about the effects of regulations. But the resulting
estimates are neither precise nor complete. Individual regulatory impact analyses vary in
rigor and rely on different assumptions, including baseline scenarios, methods, and data,
Summing across estimates involves the aggregation of analytical results that are not strictly
comparable.

How OMB’s and Crain and Crain’s Estimates Differ

It is difficult to compare OMB’s estimates of regulatory costs and Crain and Crain’s estimates
because they were constructed in very different ways, and because the presentation categories
were different (e.g., by agency in OMB’s study, and by type of regulation in the Crain and Crain
study). For several reasons, Crain and Crain’s estimates of annual regulatory costs in 2008 were
much larger than the estimates provided by OMB.

e Crain and Crain included estimates of costs associated with all rules for certain
periods, and major rules for other periods. Their estimates attempt to measure
the cumulative costs of all rules. OMB’s estimates included only major rules that
met certain criteria that had been issued during a 10-year period.

e Crain and Crain included estimates of the cost of “economic regulations,”
whereas OMB’s estimate did not include economic regulations.

* Crain and Crain included costs associated with tax paperwork, whereas OMB’s
estimate did not include tax paperwork.

Concluding Observations

Although accurate measures of the costs and benefits of all federal rules would be useful, decision
makers using studies of aggregate regulatory costs and benefits to guide public policy need to be
aware of those studies’ conceptual and methodological underpinnings. The validity and reliability
of Crain and Crain’s $1.75 trillion estimate of total federal regulatory costs in 2008 depends on
the validity and reliability of its individual elements. More than 70% of the overall estimate
($1.236 trillion) is based on the WGI index of regulatory quality for the United States, with the
authors determining the extent to which economic regulations reflected in that index reduces per
capita real GDP in the United States. However, one of the authors of the regulatory quality index
has said that Crain and Crain misinterpreted the index, and that higher values on the index cannot
be interpreted as “less stringent regulations.” Even if it could, he said that the index for the
United States should be compared to a country with a preferable index, not to an idealized “best
possible” score on the index. Comparing the United States’ regulatory quality index in 2008 to
the country with the highest index that year (Ireland) would have reduced Crain and Crain’s
estimate of the cost of economic regulations by nearly two-thirds. Other commenters (including
one of the peer reviewers of the Crain and Crain study) raised similar concerns about whether the

3:
Ibid., p. 8.

4 OMB’s report did, however, provide some information on rules issued by certain independent regulatory ag

(e.g., the Board of Governors of the Federal Reserve System and the Securities and Exchange Commission) as provided

to OMB by the Government Accountability Office. The agencies typically did not provide information on costs and

benefits.

Congressional Research Service 23
688

Analysis of an Estimate of the Total Costs of Federal Regulations

regulatory quality index could be used to measure the cost of economic regulations, and about the
regression analysis used to produce the cost estimate. Responding to these criticisms, Crain and
Crain said that they continue to believe that the regulatory quality index indicates the stringency
of a country’s economic regulations, and believe that it was appropriate for them to compare the
index for the United States to a “conceptual regulatory environment” represented by a 2.5 score
rather than to another country with a somewhat higher index score. The World Bank indicates on
its website that measures like the regulatory quality index are “often too blunt a tool to be useful
in formulating specific governance reforms in particular country contexts.”

Crain and Crain’s estimates for environmental, occupational safety and health, and homeland
security regulations were developed by mixing together academic studies (some of which were
more than 30 years old) with agencies’ estimates of regulatory costs that were developed before
the rules were issued (some of which are now 20 years old). OMB has said that adding together
diverse sets of individual studies to develop a summary measure of regulatory costs is an
“inherently flawed” approach. The agency estimates that Crain and Crain used were drawn from
OMB reports to’ Congress on the estimated costs and benefits of regulations, which were typically
presented as low-to-high ranges. However, Crain and Crain used only the highest cost estimates
from these reports, stating that they did so because the OMB estimates did not cover all
regulations, and because they believe “government agencies tend to be conservative in estimating
regulatory costs.” OMB has said that there is little documentation to support this view, and
empirical studies of agencies’ regulatory cost estimates have not resolved the issue. Also, OMB
has concluded that estimates of the costs and benefits of regulations issued more than 10 years
earlier are of “questionable relevance.” Since 2003, OMB’s annual “Regulatory Right-to-Know
Act” reports to Congress have only included information on the costs and benefits of major rules
issued during the previous 10 years. Although OMB has recognized that this approach
understates total regulatory costs and benefits, OMB has said it does not believe older estimates
are reliable or useful in informing policy decisions.

In one of its first reports to Congress on this issue, OMB also said that the incremental costs of
regulations (i.e., over and above what businesses and individuals would have done in the absence
of regulations) tend to decrease over time, as companies’ business practices and consumers’
expectations change.

Thus, although the National Highway Traffic Safety Administration has significantly
increased the safety of automobiles, it is not likely that if the agency’s regulations were
eliminated the automobile companies would discontinue the safety features that had been
mandated. Consumers demand safer cars than they used to and automobile companies are
concerned about product liability. This same phenomenon exists with the environment,
although probably to a lesser extent. Environmentally responsible behavior has become good
for the bottom line.... Over time, this “rising baseline” phenomenon reduces the true costs
and benefits of health, safety, and environmental regulations. Estimates of the aggregate
costs and benefits of regulation that include unadjusted esti from aging studies are thus

likely to be over estimates of the current costs and benefits of those regulations.

5 Office of Management and Budget, Report to Congress on the Costs and Benefits of Federal Regulations, September
30, 1997, available at http://www. whitehouse.gov/omb/inforeg_rcongress/.

Congressional Research Service 24
689

Analysis of an Estimate of the Total Costs of Federal Regulations

OMB went on to say that “it does not seem implausible that, for environmental and other social
regulations over ten years old, no more than half of compliance costs would likely be saved if
these Federal regulations magically disappeared over night.”

Crain and Crain’s estimate for the cost of tax paperwork was reportedly based on data from the
IRS and the Tax Foundation, but data in OMB’s annual Information Collection Budget suggests
that the number of hours of tax paperwork may be much higher than the authors used in their
report. On the other hand, Crain and Crain’s assumptions regarding the per hour cost of
completing the paperwork may be too high (e.g., the assumption that “human resources
professionals” paid at nearly $50 per hour would be completing all business paperwork).
However, a threshold question is whether tax paperwork should be considered in the same
category as regulatory costs. OMB does not include tax paperwork in its annual reports to
Congress on regulatory costs and benefits.

Regulatory Benefits

Although Crain and Crain attempted to determine all of the costs associated with federal
regulations, their report did not discuss the benefits of those regulations—even when information
on regulatory benefits was readily available in the OMB reports that they used to determine
regulatory costs. In their report, the authors said that it “does not address the benefits of
regulation, an important challenge that would be a logical next step toward achieving a rational
regulatory system.”*” Crain and Crain told CRS that they did not include regulatory benefits in
their study “because we researched the topic as required by the Office of Advocacy.”* The SBA
Office of Advocacy confirmed that Crain and Crain “were not asked to look at benefits, as the
task for this last iteration was to update the previous study, which also looked at costs and the
disproportionality between small and large businesses.”

Executive Order 12866 requires covered agencies to “assess both the costs and the benefits of the
intended regulation and, recognizing that some costs and benefits are difficult to quantify, propose
or adopt a regulation only upon a reasoned determination that the benefits of the intended
regulation justify its costs.” It also says that agencies should generally select regulatory
approaches that “maximize net benefits.” OMB’s reports to Congress on the aggregate costs and
benefits of federal regulations have generally indicated that the estimated benefits exceed the
estimated costs. For example, see the following:

¢ Inthe report for 2010 covering major rules reviewed by OMB from October
1999 through September 2009 for which benefits and costs were monetized, the
aggregate costs were estimated to be between $43 billion and $55 billion, and the
aggregate benefits were estimated to be between $128 billion and $616 billion.
Of the 16 major rules issued during FY2009 for which benefits and costs were

*” Crain and Crain, p. 10.
58 mail to the author from Nicole V. Crain and W. Mark Crain, March 7, 2011.

% E-mail to the author from Radwan Saade, SBA Office of Advocacy, March 7, 2011. See https://www.fbo.gow/?s=
opportunity&mode=formé&tab=core&id=8 ffd8903 7600303 8eb0e7£3 fa657£7c1&_cview=1 to view the solicitation for
this study.

1© Executive Order 12866, “Regulatory Planning and Review,” 58 Federal Register 51735, Oct, 4, 1993.

Congressional Research Service 25
690

Analysis of an Estimate of the Total Costs of Federal Regulations

monetized, the costs were estimated at between $3.7 billion and $9.5 billion, and
the benefits were estimated at between $8.6 billion and $28.9 billion.”

¢ Inthe draft report for 2011 covering major rules reviewed by OMB from October
2000 through September 2010 for which benefits and costs were monetized, the
aggregate costs were estimated to be between $44 billion and $62 billion, and the
aggregate benefits were estimated to be between $136 billion and $651 billion.
Of the 18 major rules issued during FY2010 for which benefits and costs were
monetized, the costs were estimated at between $6.5 billion and $12.5 billion,
and the benefits were estimated at between $23.3 billion and $82.3 billion.’

Each year, however, there ‘were a number of rules in which the agencies only quantified or
monetized benefits or costs, but not both. Most commonly, the agencies quantified or monetized
only costs.

Policymaking and the Crain and Crain Estimate

As noted at the beginning of this report, Crain and Crain’s estimate that federal regulations cost
$1.75 trillion in 2008 has been cited as evidence of the need for regulatory reform legislation.
However, Crain and Crain told CRS that their report was “not meant to be a decision-making tool
for lawmakers or federal regulatory agencies to use in choosing the ‘right’ level of regulation. In
no place in any of the reports do we imply that our reports should be used for this purpose. (How
could we recommend this use when we make no attempt to estimate the benefits?)”"”

As Crain and Crain suggest, information on regulatory costs alone, whether for individual rules or
for all rules in the aggregate, provides only one piece of information that Congress and other
policymakers can use in determining how to proceed. For example, even if all federal regulations
did cost $1.75 trillion in 2008 (which at least some commenters believe may not be correct), if the
monetized benefits of those regulations were determined to be greater than those costs, then
policymakers may conclude that those costs were (in the words of Executive Order 12866)
“justified.” On the other hand, if the monetized benefits of federal regulations were estimated to
be less than the estimated costs, policymakers may reach another conclusion, or may decide to
examine any non-monetized costs and benefits of those rules. But a valid, reasoned policy
decision can only be made after considering information on both costs and benefits.

0! See http://www. whitehouse. gow/sites/default/files/omb/legislative/reports/2010_Benefit_Cost_Report.pdf for a copy
of this report.

Draft_2011_CBA_Report_AllSections.pdf for a copy of this report.

103 E-mail to the author from Nicole V. Crain and W. Mark Crain, March 7, 2011.

Congressional Research Service 26
691

Analysis of an Estimate of the Total Costs of Federal Regulations

Appendix. CRS Sensitivity Analysis

In an effort to assess the sensitivity of Crain and Crain’s results, CRS ran a linear regression using
similar, but somewhat different, data and methods.'™ Specifically, CRS compiled a dataset for 30
OECD countries over the period 2002-2008 using the same dependent variable (GDP per capita
in constant 2000 dollars) and four of the five independent variables that were used by Crain and
Crain. The four identical independent variables were (1) the World Governance Indicators
regulatory quality index, (2) broadband penetration rates, (3) country population, and (4) foreign
trade as a percentage of GDP. Data for these four variables were obtained from the OECD
website (http://www.oecd.org).

Crain and Crain also included one other variable in their analysis: primary school enrollment as a
share of the eligible population. In their analysis, the associated coefficient had an unexpected
negative sign (indicating that as primary school enrollment went up, GDP per capita went down).
Crain and Crain told CRS that the negative coefficient could be due to “aging pyramid”
demographic effects. In the CRS analysis, two variables were added to account for such
demographic effects: the proportion of the population under 14 and the proportion of the
population over 65. These variables were calculated from data obtained from the U.S. Census
Bureau international population statistics."° These demographic measures may capture “aging
pyramid” effects more directly than the primary education variable.

CRS ran a cross-country fixed effects panel estimator with year indicator variables. Natural
logarithms of all variables except the regulatory quality index were used in the regression.
Estimation results using Stata 11 xtreg procedure, using robust (White) standard errors that are
used by most empirical researchers. Estimation results run with conventional standard errors,
which are very similar, are available upon request.

The estimation output is shown in Table A-1 below. The estimated coefficient on the World
Governance Indicators regulatory quality index is very small and is not significantly different
from zero. The coefficient on population is also statistically insignificant, although other
estimated coefficients have expected signs and are statistically significant at conventional levels
of confidence, ;

'* This appendix was written by (name redacted), Analyst in E ic Policy, Congressional R h Service.

15 ‘The U.S. Census Bureau International Population Data Base is available at http://www.census.gov/ipe/www/idb/
informationGateway.php. The regulatory quality index was taken from the World Bank’s World Governance Indicators
website, available at http://info. worldbank.org/governance/wgi/index.asp. The OECD data were taken from data portal
available at http://www.oecd.org.

Congressional Research Service 27
692

Analysis of an Estimate of the Total Costs of Federal Regulations

Tabie A-1. CRS Regression Analysis
Estimated determinants of log real GDP per capita

Estimated Robust
Independent Marginal Standard t-statistic P>jtj 95% Confidence Interval
Variables Contribution Error

Regulatory 0001609 0217325 0.01 0.994 -.0442871 0446089
Quality Index

Papulation (log) 2132556 .2595086 0.82 0.418 +.317499 7440102
Broadband 0233723 0035276 6.63 0.000 0161575 0305872
Penetration
Rate (log)
Percent 1.449251 .1967557 7.37 0.000 +1,851661 1.04684
Population

Under 14 (log)
Percent +.3208979 .1686001 +190 0.067 -.6657239 0239281
Population
Over 65 (log)
Foreign Trade 1051034 0493794 213 0.042 004TH .2060957
as % of GDP
(log)
sigma_u 6039017 -sigma_e 0206743
Rho 99882937 (fraction of variance due to u_i)

Source: CRS.

Notes: Estimated using fixed-effects ordinary least squares regression with year dummies, Huber/White robust
standard errors are reported.

Number of observations = 210. Number of groups = 30. Observations per group: 7. F(12,29) = 86.57.
R-square: within = 0.9003; between = 0.0521; overall = 0.0409. Corr(u_i, Xb) = -0.7610,

The point estimate of the coefficient regulatory quality index (.0001609) can be used to estimate
the economic effect of shifting the United States from the 2008 regulatory quality index value
(1.508) to the 2008 level of Ireland (1.856). According to that calculation which presumes that the
regression specification reflects the true structure of the economy, that shift would result in an
increase of $2.14 in per capita GDP (measured in year 2000 dollars). Because the point estimate
of the effect of the regulatory quality index is so imprecise, however, the calculated effect ofa
hypothetical shift of U.S. regulatory quality to the Irish level is also imprecise.

One test statistic (rho, a measure of intercountry correlation) indicates that 99.9% of the variance
in the model results from differences among countries, rather than time-series variation within
countries. This could suggest that estimating the effects of variables that generally change slowly
over time, such as the regulatory environment in economically advanced countries, may be
challenging using panel estimation methods the employ highly aggregated country-level data.
Other econometric approaches that focus on more specific changes in regulatory environment
may provide a better path for understanding the effects of regulation on economic activity.

Congressional Research Service 28
693

Analysis of an Estimate of the Total Costs of Federal Regulations

Author Contact Information

(name redacted)
Specialist in American National Government
[redacted]@crs.loc.gov, 7-....

Congressional Research Service 29
694

The Congressional Research Service (CRS) is a federal legislative branch agency, housed inside the
Library of Congress, charged with providing the United States Congress non-partisan advice on
issues that may come before Congress.

EveryCRSReport:com republishes CRS reports that are available to all Congressional staff. The
reports are not classified, and Members of Congress routinely make individual reports available to
the public.

Prior to our republication, we redacted names, phone numbers and ernail addresses of analysts
who produced the reports. We also added this page to the report. We have not intentionally made
any other changes to any report published on EveryCRSReport.com.

CRS reports, as a work of the United States government, are not subject to copyright protection in
the United States. Any CRS report may be reproduced and distributed in its entirety without
permission from CRS. However, as a CRS report may include copyrighted images or material from a
third party, you may need to obtain permission of the copyright holder if you wish to copy or
otherwise use copyrighted material.

{information in a CRS report should not be relied upon for purposes other than public
understanding of information that has been provided by CRS to members of Congress in
connection with CRS’ institutional role.

EveryCRSReport.com is not a government website and is not affiliated with CRS. We do not claim
copyright on any CRS report we have republished.
695

-8a* Research Service
LT informing the legislative debate since 1914

Methods of Estimating the Total Cost of
Federal Regulations

Updated January 21, 2016

Congressional Research Service

https://crsreports.congress. gov.
R44348

CRS REPORT
Prepared for Members. and
Comrnittees of C
696

Methods of Estimating the Total Cost of Federal Regulations

Summary

Federal agencies issue thousands of regulations each year under delegated authority from
Congress. Over the past 70 years, Congress and various Presidents have created a set of
procedures agencies must follow to issue these regulations, some of which contain requirements
for the calculation and consideration of costs, benefits, and other economic effects of regulations.
In recent years, many Members of Congress have expressed an interest in various regulatory
reform efforts that would change the current set of rulemaking requirements, including
requirements to estimate costs and benefits of regulations. As part of this debate, it has become
common for supporters of regulatory reform to comment on the total cost of federal regulation.

Estimating the total cost of regulations is inherently difficult. Current estimates of the cost of
regulation should be viewed with a great deal of caution.

Scholars and governmental entities estimating the total cost of regulation use one of two methods,
which are referred to as the “bottom-up” and the “top-down” approach. The bottom-up approach
aggregates individual cost and benefit estimates produced by agencies, arriving at a government-
wide total. In 2014, the annual report to Congress from the Office of Management and Budget
estimated the total cost of federal regulations to range between $68.5 and $101.8 billion and the
total benefits to be between $261.7 billion and $1,042.1 billion. The top-down approach estimates
the total cost of regulation by looking at the relationship of certain macroeconomic factors,
including the size of a country’s economy and a proxy measure of how much regulation the
country has. This method estimates the economic effect that a hypothetical change in the amount
of regulation in the United States might have, considering that economic effect to represent the
cost of regulation. One frequently cited study estimated the total cost of regulation in 2014 to be
$2.028 trillion, $1.439 trillion of which was calculated using this top-down approach.

Each approach has inherent advantages and disadvantages. The bottom-up approach relies on
agency estimates of the effects of specific regulations and can also be used to estimate benefits,
because agencies typically estimate both costs and benefits under current requirements so that
they may be compared and evaluated against alternatives. The bottom-up approach does not,
however, include estimates of costs and benefits of all rules, nor does it include costs and benefits
of regulations that are not monetized—meaning that the bottom-up approach is likely an
underestimate of the total cost of regulation. Furthermore, the individual estimates produced by
agencies and used in the bottom-up approach may not always be accurate.

The top-down approach can be used to estimate effects of rules that are not captured by the
bottom-up approach—such as indirect costs and costs of rules issued by independent regulatory
agencies, which are not included in the bottom-up approach—thus theoretically capturing the
whole universe of regulatory costs. Its results are, however, entirely reliant upon a number of
methodological challenges that are difficult, if not impossible, to overcome. The biggest
challenge may be finding a valid proxy measure for regulation: proxy measures of the total
amount of regulation in a country are inherently imprecise and cannot be reliably used to estimate
macroeconomic outcomes. Because of this difficulty in identifying a suitable proxy measure of
regulation, even if the total cost of regulation is substantial, it cannot be estimated with any
precision. The top-down method is intended to measure only costs; measuring costs without also
considering benefits does not provide the complete context for evaluating the appropriateness of a
country’s amount of regulation.

For these and other reasons, both approaches to estimating the total cost of regulation have
inherent—and potentially insurmountable—flaws. The discrepancy between the two approaches

Congressional Research Service
697

Methods of Estimating the Total Cost of Federal Regulations

and their associated estimates raises the question of the utility of using such figures in the
regulatory reform debate.

Congressional Research Service
698

Methods of Estimating the Total Cost of Federal Regulations

Contents

Estimating the Total Costs and Benefits of Federal Regulation ..........ssscesssssessene I

“Bottom-Up” Method: Aggregating Existing Cost Estimates 2
What Is the Bottom-Up Approach? 2
Why Use the Bottom-Up Approach? 4
Case Study: The Annual OMB Report on the Total Costs and Benefits of Federal

Rules 5
Background on the OMB Report to Congress 5
Summary of 2014 OMB Report on Costs and Benefits 5

Analysis of Bottom-Up Approach to Aggregating Costs and Benefits 7
Costs Not Estimated for Every Rule 7
Potential Uncertainties in Individual Cost-Benefit Analyses 11
Questions Over Accuracy of Individual Cost and Benefit Estimates .........scsssssseseeseseens 12
Measuring Costs over Time ........scsccsssseesscceesseeessnsesesseensees 13

“Top-Down” Method: Estimating Costs Using Macroeconomic Modeling......sssssessssersessenssnens 14

What Is the Top-Down Approach? 15

Why Use the Top-Down Approach? .......ssscsssseeseeeeneerensneseesreeneons 15

Case Study: Crain and Crain Report .......ssscsssssssssereesseseseee 15
Background on the Crain and Crain Report.......sesseeeeses 16
Summary of the 2014 Crain and Crain Report .........cscssssersssesesseeesesesserencenssenseneseenaneenes 17

Analysis of Top-Down Approach to Estimating Costs and Benefits 19
Importance of Accurate Measures of Regulation in Top-Down Approach.......sssessssssnenes 19
Questions About Proper Model Specification : 21
Other Potential Methodological Issues ve . 23
Potential for Double-Counting Costs 24

No Discussion of Benefits of Regulations 25
Summary: Advantages and Disadvantages of Two Approaches 26
Issues for COMgress ........ssssssesecssecsseseseneseresessssseseersonenssenesenraracanans 27
Contacts
Author Information 27

Congressional Research Service
699

Methods of Estimating the Total Cost of Federal Regulations

Estimating the Total Costs and Benefits of Federal
Regulation

Federal agencies issue thousands of regulations every year. These regulations are often the means
through which various government policies and programs are implemented. Many of these
regulations are administrative or routine in nature and have little or no compliance cost associated
with them.' A number of these regulations can, however, have a substantial effect on the economy
in the form of costs, benefits, and transfer payments. Over the past 70 years, Congress and
various Presidents have created a set of procedures agencies must follow to issue these
regulations, some of which contain requirements for the calculation and consideration of costs,
benefits, and other economic effects of regulations.”

Federal regulations are the product of delegated legislative authority from Congress—agencies
may promulgate regulations only with the authority from Congress to do so. As such, Congress
has shown an interest in conducting oversight of those regulations, both on the individual level
for particular regulations and also for the regulatory system as a whole. One way for Congress to
conduct oversight of the regulatory system as a whole, some say, is to monitor the total cost and
benefits of federal regulation. Comparing the estimated costs against the benefits would provide
some insight into the potential tradeoffs of regulation.

In recent years, many Members of Congress have expressed interest in various regulatory reform
efforts that would change the rulemaking process.> Proponents of these efforts argue that the
system under which agencies currently issue federal regulations is outdated, and that federal
agencies should be required to conduct more rigorous economic analysis of their regulations.‘
Opponents of these regulatory reform efforts argue that adding to federal rulemaking
requirements could cause fewer regulations to be issued by federal agencies or could create
delays in the issuance of federal regulations.° As part of this debate, it has become common for
supporters of regulatory reform to comment on the total cost of federal regulation.

' See CRS Report R43056, Counting Regulations: An Overview of Rulemaking, Types of Federal Regulations, and
Pages in the Federal Register, by Maeve P. Carey for a more detailed discussion of the nature and quantity of
regulations issued each year.

2 For an overview of the federal rulemaking process, see CRS Report RL32240, The Federal Rulemaking Process: An
Overview, coordinated by Maeve P. Carey.

3 For example, in January 2015, the House of Representatives passed H.R. 185, the Regulatory Accountability Act of

2015, which would make several changes to the current rulemaking process, including instituting more extensive cost-
benefit analysis requirements.
4 For example, see U.S. Congress, House C ittee on the Judiciary, Sub ittee on Courts, C cial and

Administrative Law, APA at 65: Is Reform Needed to Create Jobs, Promote Economic Growth, and Reduce Costs?,
112" Cong., 1* sess., February 28, 2011, 112-17 (Washington: GPO, 2011); and Business Roundtable, Using Cost-
Benefit Analysis To Create Smart Regulation: A Primer and Key Considerations for Congress and Federal Agencies,
December 2014, http://busi »undtable.org/sites/default/files/reports/BRT%20Cost-Benefit%20Analysis.pdf.

5 See, for example, the debate over rulemaking “ossification,” which suggests that the addition of analytical
requirements—along with other procedural requirements—has slowed the rulemaking process. See Thomas O.
McGarity, “Some Thoughts on ‘Deossifying’ the Rulemaking Process,” Duke Law Journal, vol. 41, no. 6 (June 1992),
pp. 1385-1462; Jason Webb Yackee and Susan Webb Yackee, “Administrative Procedures and Bureaucratic
Performance: Is Federal Rule-making ‘Ossified’?” Journal of Public Administration Research and Theory, vol. 20
(2010), pp. 261-282; and Richard J. Pierce, Jr., “Rulemaking Ossification Is Real: A Response to Testing the
Ossification Thesis,” George Washington Law Review, vol. 80, no. 5 July 2012), pp. 1493-1503.

Congressional Research Service R44348 - VERSION 2 - UPDATED 1
700

Methods of Estimating the Total Cost of Federal Regulations

Estimating the total cost of regulations is inherently difficult. Current estimates of the cost of
regulation should be viewed with a great deal of caution.

Scholars attempting to identify an estimate for the total cost of regulation have taken two primary
approaches that lead to radically different conclusions about the total economic effect of
regulation. In this report, these two approaches are referred to as the “bottom-up” and the “top-
down” approaches or methods. In short, the bottom-up approach aggregates individual cost
estimates produced by federal agencies. The top-down approach relies on macroeconomic
modeling to find a causal relationship between larger economic factors, such as gross domestic
product (GDP), and a proxy measure intended to represent the overall amount of regulation.°

The two approaches use entirely different methods and produce radically different results. In
2014, the most frequently cited cost estimates resulting from each of these studies ranged from
$57-$87 billion (using the bottom-up method) to $2 trillion (the majority—almost $1.5 trillion—
of which was arrived at using the top-down method).’

This report analyzes these two approaches for estimating the total cost of federal regulations. In
discussing each approach, the report provides an overview of the advantages, a brief case study,
and an analysis of the potential issues or inherent problems using the case study to illustrate the
concepts.

The objective of this report is not to provide an estimate of the total costs and benefits of federal
regulations, but rather, to inform the broader regulatory reform debate by identifying the
difficulties in providing such estimates and potential problems inherent in the methods that exist.

“Bottom-Up” Method: Aggregating Existing Cost

Estimates

The first approach to aggregating the total costs and benefits of federal rules is generally referred
to as a “bottom-up” approach.

What Is the Bottom-Up Approach?

This method relies on estimates of costs and benefits that agencies produce during the rulemaking
process, pursuant to several requirements.* The bottom-up approach aggregates these estimates of
costs and benefits that agencies calculate in individual rulemakings, using the sum as a
government-wide total. Understanding the requirements under which agencies conduct these
estimates—specifically, knowing when agencies are required to estimate costs and benefits, and
when they are not—is important for understanding the advantages and disadvantages of the
bottom-up approach.

The primary requirement for most agencies to calculate estimates of costs and benefits when
issuing rules is under Executive Order 12866.° That executive order requires covered agencies to

ion or a model.

6 A proxy measure is a figure that is used to rep the value of something in a
7 To compare these figures, CRS adjusted the bottom-up numbers to be in 2014 dollars.

® For a detailed explanation of these requirements, see CRS Report R41974, Cost-Benefit and Other Analysis
Requirements in the Rulemaking Process, coordinated by Maeve P. Carey.

° Executive Order 12866, “Regulatory Planning and Review,” 58 Federal Register 51735, October 4, 1993. For more
detailed information about this and other cost-benefit analysis requi in the rulemaking process, see CRS Report
R41974, Cost-Benefit and Other Analysis Requirements in the Rulemaking Process, coordinated by Maeve P. Carey.

Congressional Research Service R44348 - VERSION 2 - UPDATED 2
701

Methods of Estimating the Total Cost of Federal Regulations

assess costs and benefits for “economically significant” rules at the proposed and final rule
stage.'° Economically significant rules are defined in the executive order as those that may “have
an annual effect on the economy of $100 million or more or adversely affect in a material way the
economy, a sector of the economy, productivity, competition, jobs, the environment, public health
or safety, or State, local, or tribal governments or communities.”!! The term “effect on the
economy” means that a rule may be considered economically significant if it has costs or benefits
of over $100 million.!? Other provisions of Executive Order 12866 encourage agencies to
consider costs and benefits during the rulemaking procegs for all rules, although those other
provisions do not require a complete, detailed cost-benefit analysis for non-economically
significant rules.'3 Executive Order 12866, issued by President Clinton, has remained in effect
since 1993, and it was reaffirmed in 2011 by President Obama in Executive Order 13563.'* The
estimates that agencies produce under Executive Order 12866 are subject to review by the Office
of Management and Budget (OMB). Specifically, agencies submit their rules and cost-benefit
analyses to OMB’s Office of Information and Regulatory Affairs (OIRA), the agency within
OMB responsible for reviewing regulations and cost-benefit analyses. OMB has issued a number
of guidance documents agencies are required to follow when estimating costs and benefits of

In addition to these executive order requirements, certain statutory requirements for cost-benefit
analysis, or other types of regulatory impact analysis, sometimes require agencies to calculate
costs, benefits, and other economic effects of rules. The Regulatory Flexibility Act (RFA) requires
regulatory impact analyses for proposed and final rules that will have a “significant economic
impact on a substantial number of small entities.” Title II of the Unfunded Mandates Reform
Act (UMRA) requires agencies to analyze and reduce costs associated with federal mandates

10 This requirement for cost-benefit analysis in Executive Order 12866 does not extend to the independent regulatory
agencies listed at 44 U.S.C. § 3502(5), which includes, for example, the Federal Reserve and the Securities and
Exchange Commission. For more information about the exclusion of the independent regulatory agencies from this
cost-benefit analysis requirement, see CRS Report R42821, Independent Regulatory Agencies, Cost-Benefit Analysis,
and Presidential Review of Regulations, by Maeve P. Carey and ‘Michelle D. Christensen.

' Executive Order 12866 § 3(f)(1).

"2 This phrase also includes transfer rules that transfer sums of over $100 million. For a more detailed analysis of the
definition of “major” rules, see CRS Report R41651, REINS Act: Number and Types of “Major Rules” in Recent
Years, by Maeve P. Carey and Curtis W. Copeland.

3 For example, Section 1(b)(6) requires agencies to “assess both the costs and the benefits of the intended regulation
and, recognizing that some costs and benefits are difficult to quantify, propose or adopt a regulation only upon a
reasoned determination that the benefits of the intended regulation justify its costs.” Section 1(b)(11) requires agi

to “tailor [their] regulations to impose the least burden on society,” while “obtaining the regulatory objectives, taking
into account, among other things, and to the extent t practicable, the costs of cumulative regulations.” These provisions
are considered to be more like guiding princir , rather than specific requi for cost-benefit

4 Executive Order 13563, “Improving R and Regulatory Review,” 76 Federal Register 3821, January 21,
2011.

'5 For example, in 2003, OMB issued Circular A-4 to provide guidance to agencies on how to conduct cost-benefit
analysis. See Office of Management and Budget, Circular A-4, “Regulatory Analysis,” September 17, 2003, at
http://www. whiteh gov/omb/assets/regi ‘y_matters_pdf/a-4.pdf. This guidance provides information such as
what discount rates agencies should use, how to choose a time period for estimating future costs and benefits, etc. Since
2003, OMB has issued several additional guidance documents to provide instruction to agencies on complying with

gulatory analysis requi
16 The phrase “small entities” is considered in the RFA to include small busi local gover and not-for-
profit organizations. 5 U.S.C. §§601-612. For more information about requi of the Regulatory Flexibility Act,
see CRS Report RL34355, The Regulatory Flexibility Act: Impl: ion Issues and Proposed Reforms, di

by Maeve P. Carey.

Congressional Research Service R44348 - VERSION 2 - UPDATED 3
702

Methods of Estimating the Total Cost of Federal Regulations

upon state, local, and tribal governments and the private sector.'? However, in practice, the RFA
and UMRA apply to a fairly small number of rules. Finally, agencies may be required under their
own authorizing statutes to calculate and/or consider the costs and benefits of their rules.

The bottom-up approach for estimating costs and benefits aggregates the estimates produced
under these requirements, producing a total, government-wide figure for the costs and benefits of
regulation.

Why Use the Bottom-Up Approach?

The bottom-up approach to estimating the costs and benefits of federal regulation has several
potential benefits. First, this approach sums up actual estimates of costs and benefits that agencies
have calculated for individual regulations, and, as described above, most of these estimates have
undergone review from OMB.

Second, under the requirements discussed above, agencies estimate both costs and benefits, which
allows the bottom-up approach to compare total estimated costs to total estimated benefits. Such
information can be valuable for evaluation of cost-effectiveness of regulation generally (i.e., what
the benefits received are for the costs invested) and it allows for calculation and evaluation of a
ratio of costs to benefits.

Third, the components of the bottom-up approach to measuring costs and benefits could be
validated by conducting analysis ex post, or after the fact, of what the costs and benefits of
specific regulations actually turned out to be.'® This could be done, for example, as part of
agencies’ retrospective review process, in which agencies reanalyze existing rules and may
consider making amendments to those rules in light of the ex post analysis. Agencies do not
always conduct retrospective review of their regulations, however, and a retrospective review
does not necessarily include a reevaluation of the initial cost-benefit analysis to test its accuracy.’
But some such studies have been conducted in recent years by scholars and observers of the
regulatory process.”°

Despite these and other potential advantages of using a bottom-up approach to aggregating costs
and benefits, certain issues—and potential caveats—should be taken into consideration. To help
illustrate some of these issues, this report first introduces a case study: the most well-known and
widely cited bottom-up study of the total costs and benefits of regulation. The report then uses the
case study to analyze and discuss some of the problems with a bottom-up study.

172 U.S.C, §§1532-1538. For more information about UMRA, see CRS Report R40957, Unfunded Mandates Reform
Act: History, Impact, and Issues, by Robert Jay Dilger and Richard S. Beth.

18 Ex ante esti are those conducted by agencies prior to a regulation being issued or taking effect, and they reflect
the agency’s prediction of what the effects of the regulation will be. Ex post esti are done pectively—that is,
after the regulation has been issued and taken effect—and they are used to evaluate the accuracy of the initial estimate
and/or the effectiveness of the regulation.

'° Go wide pective reviews have been required since the Carter Administration, and most recently have
been required by the Obama Administration in E ive Order 13563.

20 See the section below entitled “Questions Over Accuracy of Individual Cost and Benefit Estimates” for an overview
of this literature,

Congressional Research Service R44348 - VERSION 2 - UPDATED 4
703

Methods of Estimating the Total Cost of Federal Regulations

Case Study: The Annual OMB Report on the Total Costs and
Benefits of Federal Rules

The most well-known bottom-up study is the report to Congress on the benefits and costs of
federal rules, which OMB compiles annually.?!

Background on the OMB Report to Congress

Since the 1990s, OMB has estimated the total costs and benefits of federal regulations pursuant to
various federal requirements. The initial requirement was in Section 645 of the Treasury, Postal
Service and General Government Appropriations Act, 1997,2? which required the Director of
OMB to submit a report by September 30, 1997, that provided—among other things-—‘“estimates
of the total annual costs and benefits of federal regulatory programs, including quantitative and
nonquantitative measures of regulatory costs and benefits.” Similar requirements were contained
in other appropriations bills in subsequent years; as of 2015, the current requirement for OMB to
report on the total annual costs and benefits of federal regulations is under the Regulatory Right-
to-Know Act, which was enacted in 2000 as part of the Treasury and General Government
Appropriations Act for FY2001.”3 That provision required OMB to submit to Congress each year,
along with the President’s budget,

An accounting statement and associated report containing-

(1) an estimate of the total annual costs and benefits (including quantifiable and
nonquantifiable effects) of Federal rules and paperwork, to the extent feasible- (A) in the
aggregate; (B) by agency and agency program; and (C) by major rule;

(2) an analysis of impacts of Federal regulation on State, local, and tribal government,
small business, wages, and economic growth; and

(3) recommendations for reform.

OMB has submitted a report to Congress each year with a total of the costs and benefits produced
by federal agencies pursuant to the requirements discussed above.

Summary of 2014 OMB Report on Costs and Benefits

The 2014 report to Congress on the costs and benefits of federal regulations was published in
June 15, 2015.4 The principal findings of the 2014 report were as follows:?°

« The estimated annual benefits of major federal regulations reviewed by OMB
from October 1, 2003, to September 30, 2013, for which agencies estimated and
monetized both benefits and costs, are in the aggregate between $281.0 billion

21 These reports are available on OMB’s website. See http://www. whitehouse.gov/omb/
inforeg_regpol_reports_congress/.
2 PL, 104-208.

3 PL. 106-554, §1(a)(3) [title VI, §624], 114 Stat. 2763.

%4 The Draft 2015 report was released in October 2015, but had not yet been finalized as of the time of writing of this

report.

25 Office of Management and Budget, 20/4 Report to Congress on the Benefits and Costs of Federal Regulations and
Unfunded Mandates on State, Local, and Tribal Entities, available at https://www. whitehouse. gov/sites/default/files/

omb/inforeg/2014_cb/2014-cost-benefit-report.pdf.

Congressional Research Service R44348 - VERSION 2 - UPDATED. 5
704

Methods of Estimating the Total Cost of Federal Regulations

and $1,119.0 billion, while the estimated annual costs are in the aggregate
between $73.6 billion and $109.3 billion. These ranges reflect uncertainty in
the benefits and costs of each rule at the time that it was evaluated (prior to
promulgation).

The OMB reports demonstrate that agencies do not provide quantified and/or monetized
information for every rule. For example, below is information on how frequently agencies
provided quantified and/or monetized estimates of costs and benefits:

e During FY2013, executive agencies promulgated 54
major rules, of which 30 were “transfer” rules.?’
Transfer rules usually implement federal budgetary
programs as required or authorized by Congress,
such as rules associated with the Medicare Program
and the Federal Pell Grant Program, and are
categorized differently by OMB because they cause
income transfers from federally collected tax dollars
to program beneficiaries—meaning they “may not
impose significant regulatory costs on the private
sector.””* In all but one of the 30 transfer rules listed
in the report, the issuing agencies quantified and
monetized the transfer amounts.

« In7 of the remaining 24 major rules issued in
FY2013, the agencies quantified and monetized both benefits and costs, Those
seven rules were estimated to result in a total of $33.2 billion to $87.4 billion in
annual benefits, and $2.6 billion to $3.2 billion in annual costs.”°

e In two of the major rules, the agency was able to quantify and monetize only
benefits. For these two rules, the agencies estimated annual benefits of $500
million to $655 million.

e In 11 major rules, the agencies quantified and monetized only costs, and in one
case only partially. For these 11 rules, the agencies estimated total annual costs of
about $1.6 billion to $2.3 billion?!

¢ In four major rules, the agencies did not quantify or monetize costs or benefits.

26 The numbers cited here in this CRS report are inflation-adjusted to 2014 dollars. OMB reported the totals in both 2001
and 2010 dollars.
27 As explained by OMB i int the Teport, “budgetary transfer rules are rules that primarily cause income transfers usually
from taxpayers top et iaries” (p.8). Examples listed in the 2014 report included various education loan

d by the Dep of Education, major capital in ini d by! the
Department of Transportation, and rules implementing the Supplemental Nutritional Assist: Py i
by the Department of Agriculture (see pp. 29-31 for a complete list of the major transfer rules).

38 2014 OMB Report, p. 8.

29 The numbers cited here were inflation-adjusted by CRS to 2014 dollars. OMB reported the numbers in 2001 and 2010
dollars (see p, 24).

3° It appears, though it is not entirely clear, that these numbers are reported in 2001 dollars (see p. 2). Adjusted for
inflation to 2014 dollars, the estimated range of benefits for these two rules would be $648.8 million to $850.0 million.

31 It appears, though it is not entirely clear, that these numbers are reported in 2001 dollars (see p. 2). Adjusted for
inflation to 2014 dollars, the estimated range of costs for these 11 rules would be $2.1 billion to $3.1 billion,

Congressional Research Service R44348 - VERSION 2 - UPDATED 6
705

Methods of Estimating the Total Cost of Federal Regulations

Analysis of Bottom-Up Approach to Aggregating Costs and
Benefits

A bottom-up approach, such as that taken by OMB, is likely to result in an underestimate of the
total cost of federal regulations. Agencies are not required to conduct a cost-benefit analysis for
every rule, and the bottom-up approach can only include costs and benefits that have actually
been estimated. Furthermore, estimates of costs and benefits that agencies produce are primarily
intended to inform decisionmakers about an individual rule, but aggregating the information
causes the context and understanding of potential uncertainties in each individual estimate to be
lost. Finally, a decision must be made about how many years’ worth of rules to include in the
aggregated estimate of costs and benefits, but this is likely to leave out costs and benefits of rules
that were issued prior to the period included.

Costs Not Estimated for Every Rule

One of the main challenges to calculating accurately the total costs and benefits of federal
regulations is that agencies are not required to estimate costs and benefits for all regulations.
Without an estimated cost or benefit for every rule, it is impossible to arrive at a total dollar
amount for all rules—the aggregated costs and benefits will only include those rules for which a
monetized estimate exists.

Independent Regulatory Agencies Are Often Not Required to Estimate Costs and
Benefits

First, not all agencies are subject to cost-benefit analysis requirements. The cost-benefit analysis
requirement does not apply to independent regulatory agencies, a class of agencies that were
created by Congress to have various characteristics of independence from the President.*

Although some of the independent regulatory agencies have agency-specific instructions in
statute to consider certain effects of their regulations, others are not specifically required to
conduct cost-benefit analysis or monetize costs and benefits.*? According to OMB’s 2014 report
on costs and benefits, the independent regulatory agencies issued 18 major rules in FY2013. Of
those 18 rules, the agencies appear to have provided some information on either costs or benefits
in 12 rules.*4

32 These agencies are listed at 44 U.S.C. 3502(5), When he issued Executive Order 12866, President Clinton chose not
to include those agencies in the order’s requirements for OMB review and cost-benefit analysis. President Reagan had

made the same decisi lude the i d hen he issued the predecessor order in
1981. See Executive Order 1 12291, “Federal Regulation,” 46 Federal ai 13193, February 19, 1981. For more
discussion of this decision, see CRS Report R42821, independ ig Cost-Benefit Analysis, and
Presidential Review of R ions, by Maeve P. Carey and Michelle D. Chri Forad ion of ch istics

of agency independence more generally, see CRS Report R43391, Incdopontdence of Federal Financial Regulators, by
Henry B. Hogue, Marc Labonte, and Baird Webel, and CRS Report R43562, Administrative Law Primer: Statutory
Definitions of “Agency” and Characteristics of Agency Independence, by Jared P. Cole and Daniel T. Shedd,

33 For a more detailed discussion about what agency- specific requirements may apply to these agencies, see CRS

Report R42821, Independent R Ag Cost-Benefit Analysis, and Presidential Review of Regulations, by
Maeve P, ari and Michelle D.! Christensen, and Curtis W. Copeland, Economic Analysis and Independent

ies, report prepared for the iderati of the Administrative Conft of the United States, April
30, , 201 3, https: Jiwww.acus.gov/sites/default/files/d ‘Copeland%20Final%20BCA%20Report%204-30-13,pdf.

44 Office of Management and Budget, 2014 Report to Congress on the Benefits and Costs of Federal Regulations and
Unfunded Mandates on State, Local, and Tribal Entities, available at https://www. whitehouse.gov/sites/default/files/

Congressional Research Service R44348 « VERSION 2 - UPDATED 7
706

Methods of Estimating the Total Cost of Federal Regulations

Because most cost-benefit analysis requirements do not extend to the independent regulatory
agencies, the bottom-up approach to estimating the costs and benefits of regulation does not
include costs and benefits of regulations issued by those agencies. This includes, for example,
many of the financial regulations issued pursuant to the Dodd-Frank Wall Street Reform and
Consumer Protection Act of 2010, which are primarily issued by the financial regulators—most
of which are excluded from the cost-benefit requirement of Executive Order 12866.*> The
exclusion of certain types of agencies from cost-benefit analysis requirements is a weakness in
the annual OMB reports and presents a challenge to bottom-up approaches of estimating costs
and benefits. The OMB reports generally identify the number of rules issued by independent
regulatory agencies that provide some information on some costs and/or benefits, but they do not
typically have information about the magnitude of those costs or benefits.

Costs and Benefit Estimates Only Required for Economically Significant Rules

Second, the agencies that are subject to cost-benefit analysis requirements are not required to
conduct a cost-benefit analysis for every rule—only those rules that are deemed economically
significant, as defined by Executive Order 12866. Specifically, the order defines economically
significant rules as those that have an annual effect on the economy of at least $100 million.
Rules that are significant, but not economically significant, are subject to requirements for OIRA
review and may have a less formal assessment of costs and benefits, but agencies are not
generally required to conduct a complete cost-benefit assessment for those rules.*” As such, the
rules included in the OMB reports’ total estimates of costs and benefits are only economically
significant rules.>8

Monetizing Costs Can Be Challenging

Third, quantifying and monetizing certain costs and benefits can be very difficult, and agencies
do not often monetize all of the expected effects of their regulations. The bottom-up approach,
however, is limited to totaling only those costs and benefits that are actually monetized. Under
current rulemaking requirements, agencies are encouraged, but not necessarily required, to
monetize costs and benefits.*? For example, Executive Order 12866 states that agencies should
provide a quantification of costs and benefits “to the extent feasible.”*°

omb/inforeg/2014_cb/2014-cost-benefit-report.pdf. In the table, the report indicates that seven rules have monetized
costs and benefits, but it appears that the table may have added the numbers incorrectly.

35 PLL. 111-203.

36 Economically significant rules are those that may “have an annual effect on the economy of $100 million or more or
adversely affect in a material way the economy, a sector of the economy, productivity, competition, Jobs, the
environment, public health or safety, or State, local, or tribal gover or ies” (E: ve Order 12866

37 Rules that are “significant” but not “economically significant” are required to undergo OMB review under Executive
Order 12866. OMB’s website, www.Reginfo.gov, provides data on the number of “significant” rules that OMB reviews
each year (but not on the number of those rules that agencies issue each year). The data on OMB reviews show that the
number of such rules reviewed each year is approximately in the range of 100-250; this is likely very similar to the
number of such final rules issued each year.

38 These rules are referred to in the OMB reports as “major” rules, Although the definitions of “major” rules and

ly significant” rules in slight diffe the two terms are often used interchangeably.
3° Under Executive Order 12866, the term “significant” rule encompasses a much broader number of rules than those
idered “ ically significant.” For “signifi icant” tules, agencies are asked to conduct an initial of
costs and benefits, but not a compl t-benefit analysis.

49 Executive Order 12866 §6(a\(3)(C)).

Congressional Research Service R44348 - VERSION 2 - UPDATED 8
707

Methods of Estimating the Total Cost of Federal Regulations

Monetizing the effects of regulations involves converting expected effects, such as costs to
consumers or changes to a population’s health or behavior, into dollar terms. Monetizing the
effects of regulations involves turning costs and benefits into a common unit—dollars—so that
they can be compared against one another. This can allow for an evaluation of the cost-
effectiveness of a rule, such as a calculation of the cost of each life expected to be saved by a rule,
or the cost-benefit ratio of a rule.

Although some of the effects of a rule can be measured fairly easily in dollar terms, such as
certain types of equipment or technologies for which a market value can be easily identified,
other effects are more difficult to monetize. In cases in which dollar amounts are not readily
available, agencies often rely on economic techniques that attempt to simulate market exchanges.
One method agencies use to monetize certain concepts is based on a formula that includes
monetized values known as “willingness-to-pay” or “willingness-to-accept” to measure the value
that individuals place on the change resulting from a particular regulation.*! This allows an
agency to assign a dollar value to a regulatory outcome that may not otherwise have an easily
identifiable value, and then the estimate can be compared against the costs of obtaining that
benefit. For example, agencies sometimes use the “value of a statistical life” or “VSL” to assign a
monetized amount to the benefits per life saved from certain types of regulations.” The agency
can then compare this monetized estimate of benefits against the costs of the rule to see whether
the rule’s costs were justified by its benefits.

The executive orders and OMB guidance documents recognize that quantification and
monetization can be difficult in some cases and allow agencies some flexibility in determining
when effects can be quantified and monetized:

e Executive Order 12866 instructs agencies to provide information on the
quantified costs of the anticipated costs and benefits of regulations “to the extent

© OMB Circular A-4, which OMB issued in 2003 to provide guidance to agencies
on how to conduct cost-benefit analysis, states that agencies “should develop
quantitative estimates and convert them to dollar amounts if possible. In many

41 In recent decades, as the use of cost-benefit analysis has increased, | a debate has emerged about the appropriateness
of monetizing certain costs and benefits in lation, While lly favor the notion of assigning a
monetized value to certain things like risks to life and health, others have opposed the monetization of certain effects of
lation. See, for ple, W. Kip Viscusi, “Monetizing the Benefits of Risk and Environmental Regulation,”
Fordham Urban Law Journal, vol. 33, no. 4 (2005); W. Kip Viscusi, “What’s to Know? Puzzles in the Literature on
the Value of a Statistical Life,” Journal of Economic Surveys, vol. 26, no. 5 (2011); and Robert W. Hahn, Jn Defense of
the Economic Analysis of Regulation, (AE! Press, 2005). Others argue against this type of valuation; see Frank
Ackerman and Lisa Heinzerling, Priceless: On Knowing the Price of Everything and the Value of Nothing (New York:
The New Press, 2004).
® The VSL is calculated based upon a willing to-pay model. For ple, if 100,000 people are willing to pay $60
to eliminate a 1 in 100,000 risk of a certain event, such as dying from a particular type of disease, then an agency will
multiply the $60 payment times the number of individuals in the population (100,000), yielding a total of $6 million. If
a tule is expected to save 100 lives, then the total benefits that can be expected to come from the rule would include
$600 million in lives saved (100 lives times $6 million). According to a 2011 OMB guid: di current agency
practice uses a VSL ranging from “roughly $5 million to $9 million per statistical life.” Office of Management and
Budget, “Regulatory Impact Analysis: A Primer,” August 15, 2011, p. 10. See also CRS Report R41140, How Agencies
Monetize “Statistical Lives” Expected to Be Saved By Regulations, by Curtis W. Copeland. The author of that report is
no longer at CRS; congressional clients with questions about its may be di d to the author of this report.

43 Executive Order 12866 §6(a\(3)(C).

Congressional Research Service R44348 - VERSION 2 - UPDATED 9
708

Methods of Estimating the Total Cost of Federal Regulations

cases, quantified estimates are readily convertible, with a little effort, into dollar

e Executive Order 13563, which President Obama issued in January 2011, stated
that “Where appropriate and permitted by law, each agency may consider (and
discuss qualitatively) values that are difficult or impossible to quantify, including
equity, human dignity, fairness, and distributive impacts.” *

* OMB’s 2011 guidance document, “Regulatory Impact Analysis: A Primer,”
instructs agencies to quantify the costs and benefits in terms of units—for
example, the number of premature deaths avoided each year or the number of
prevented nonfatal illnesses—as well as monetizing the costs and benefits
associated with each of these effects, to the extent possible.”

As OMB explained in its 2014 report,

When agencies have not quantified or monetized the primary benefits or costs of
regulations, it is generally because of conceptual and empirical challenges, including an
absence of relevant information. Many rules have benefits or costs that cannot be quantified
or monetized with existing information, and the aggregate estimates presented here do not
capture those non-monetized benefits and costs. In some cases, quantification of various
effects is highly speculative, For example, it may not be possible to quantify the benefits
of certain disclosure requirements, even if those benefits are likely to be large, simply
because the impact of some of these requirements cannot be specified in advance.*’

Practitioners or observers of the rulemaking process do not necessarily agree on what effects are
appropriate to monetize. For example, the Obama Administration has placed greater emphasis
than earlier Administrations on the value of qualitative benefits such as equity and dignity.**
Debates in the literature have raised questions over when it may be appropriate to quantify or
monetize certain qualitative effects of rules. For example, questions have been raised as to
whether dignity and other psychological effects of rules, such as fear and anxiety, should be
monetized in regulatory impact analyses.”

In sum, to achieve an accurate assessment of the total costs and benefits of regulations in dollar
terms using a bottom-up method, one would have to monetize all possible effects of regulation,
and such an undertaking is not consistent with current rulemaking requirements or practice. OMB
did state in its 2014 report, however, that OMB believes “the benefits and costs of major rules,

“4 Office of Management and Budget, Circular A-4, “Regulatory Analysis,” September 17, 2003. The circular is
available at http://www.whitehouse.gov/omb/assets/regulatory_matters_pdf/a-4.pdf.

4 Executive Order 13563, “Improving Regulations and Regulatory Review,” 76 Federal Register 3821, January 21,
2011.

4 See Office of M: and Budget, “Regulatory Impact Analysis: A Primer,” August 15, 2011, at
primer.pdf.

472014 OMB Report, pp. 1-3.

4 For a discussion of this and other differences between the Obama, George W. Bush, and Clinton Administrations’
priorities for cost-benefit analysis and OIRA review, see Art Fraas and Richard Morgenstern, “Identifying the
Analytical Implications of Alternative Regulatory Philosophies,” Journal of Benefit Cost Analysis, vol. 5, no. 1 (2014),
pp. 137-171.

4 See Rachel Bayefsky, “Dignity as a Value in Agency Cost-Benefit Analysis,” Yale Law Journal, vol. 123, no. 6
(April 2014), pp. 1732-1782, at http://www. yalelawjournal.org/pdf/1732.Bayefsky.1782_uS2fptmb.pdf; and Matthew
D, Adler, “Fear Assessment: Cost-Benefit Analysis and the Pricing of Fear and Anxiety,” Chicago-Kent Law Review,
vol. 79, no. 3 (January 2004), pp. 977-1053, at http://scholarship.kentlaw.iit.edu/cgi/viewcontent, cgi?article=3459&
context=cklawreview,

Congressional Research Service R44348 - VERSION 2 - UPDATED 410
709

Methods of Estimating the Total Cost of Federal Regulations

which have the largest economic effects, account for the majority of the total benefits and costs of
all rules subject to OMB review.”

Given that agencies do not estimate cost and benefits for every rule issued in every year,
estimates that use the bottom-up approach are likely under-reporting costs and benefits, On the
other hand, as discussed more below, some of the literature evaluating the quality and accuracy of
cost-benefit analyses has suggested that costs and benefits for rules evaluated are overestimated
by agencies,

Potential Uncertainties in Individual Cost-Benefit Analyses

Cost-benefit estimates are produced by agencies to assist with decisionmaking in individual rules,
and the estimates often contain some uncertainty from not knowing precisely the potential effects
of rules. For example, consider a rule in which an agency conducts a risk assessment, such as an
airline safety rule intended to lower the risk of a terrorist attack on the United States. The estimate
of costs and benefits for this rule would contain a great deal of underlying uncertainty, because
precisely estimating the projected decrease in the risk of a terrorist attack and the precise cost of
the rule is likely impossible. On the other hand, a rule that would result in changes that can be
more easily predicted and measured, such as a rule requiring the purchase of new safety
equipment for a vehicle fleet, is likely to contain less uncertainty.

To attempt to reduce uncertainty and produce high-quality, robust estimates, current requirements
and guidance documents encourage agencies to base their estimates on the best reasonable
obtainable scientific, technical, and economic information. With regard to uncertainties, agencies
are instructed to analyze and present them as part of the overall regulatory analysis.*' This
generally results in the agencies producing a range of estimates of costs and benefits and using
certain types of analytical techniques (e.g., sensitivity analysis) to identify how benefits and costs
of a rule would change due to changes in key variables.

As stated in a 1996 article outlining the challenges of uncertainty in cost-benefit analysis (also
referred to as benefit-cost analysis),

Benefit-cost analysis can help decision-makers better understand the implications of
decisions by identifying and, where appropriate, quantifying the favorable and unfavorable
consequences of a proposed policy change, even when information on benefits and costs,
is highly uncertain. In some cases, however, benefit-cost analysis cannot be used to
conclude that the economic benefits of a decision will exceed or fall short of its costs,
because there is simply too much uncertainty.

In adding the results of all the individual studies together, however, the context and uncertainties
of each individual study may be lost. As OMB stated in its first report on costs and benefits,

Studies that have attempted to total up the total costs and benefits of Federal regulations
have basically added together a diverse set of individual studies. Unfortunately, these
individual studies vary in quality, methodology, and type of regulatory costs included. Thus

$9 2014 OMB report, p. 23.
51 See, for ple, Office of Manag and Budget, “Regulatory Impact Analysis: A Primer,” August 15, 2011, p.
14. .

52 Kenneth J. Arrow, Maureen L. Cropper, George C. Eads, Robert W. Hahn, Lester B. Lave, Roger G, Noll, Paul R.
Portney, Milton Russell, Richard Schmalensee, V. Kerry Smith, and Robert N. Stavins, “Is There a Role for Benefit-
Cost Analysis in Environmental, Health, and Safety Regulation?” Science, April 12, 1996, vol. 272, pp. 221-222.

Congressional Research Service R44348 - VERSION 2 - UPDATED. 41
710

Methods of Estimating the Total Cost of Federal Regulations

we have an apples and oranges problem, or, more aptly, an apples, oranges, kiwis,
grapefruit, etc., problem.*

Adding together existing estimates of costs and benefits treats the individual estimates as though
they are precise estimates, but they may be imprecise estimates. “CBA can sometimes produce an
illusion of certainty,” as one former OIRA Administrator stated. This illusion of certainty can be
misleading in individual cost and benefits estimates, and it becomes even more so when such
estimates are aggregated. ** In any individual estimate of costs and benefits, “numerous technical
judgments must be made, and technical analysts might well disagree.”*> Aggregating all of the
bottom-up estimates that agencies have produced can cause the context and any important caveats
or reflections of uncertainty in each regulatory impact analysis to be lost.

Questions Over Accuracy of Individual Cost and Benefit Estimates

Uncertainty in how best to estimate costs and benefits leads to the question of whether the results
are accurate—i.e., whether agencies overestimate or underestimate costs and benefits. Proponents
of regulation tend to argue that agencies overestimate costs of regulation.** On the other hand,
opponents of regulations tend to argue that agencies underestimate costs—agencies may have
incentives to underestimate the costs of regulations and overestimate the benefits, which would
help to make the case for promulgating a regulation because of its positive net benefits.°’ To
address this important question, a number of studies have examined the accuracy of agency
estimates of costs and benefits. One academic study published in 2000 compared ex ante studies
to ex post studies and found that agencies frequently overestimated both costs and benefits of
regulations.** In 2010, the same authors performed a similar ex post study of several cost-benefit
estimates that had been produced by agencies subsequent to their 2000 study. Again, they
concluded that regulatory agencies tended to overestimate the total costs of regulations,
explaining that “a variety of factors contribute to initial government agency cost estimates that
may differ from the realized results, although in some cases this is coincident with differences in
benefits produced by regulations.”*°

In its 2005 report to Congress on the costs and benefits of regulations, OMB included a chapter
on “validation” of cost estimates. OMB examined a number of ex ante cost-benefit estimates

53 Office of Management and Budget, Report to Congress on the Costs and Benefits of Federal Regulations, Septemt
30, 1997, ch. 2, at https://www. whitehouse.gov/omb/inforeg_chap2.

54 Cass R. Sunstein, “The Arithmetic of Arsenic,” Georgetown Law Journal, vol. 90, no. 7 (July 2002), p. 2258.

5 Cass R. S' in, “Financial Regulation and Cost-Benefit Analysis,” Yale Law Journal Forum, January 22, 2015, p.
266, at http://www.yalelawj Lorg/pdf/S inPDF_4nfid4ar.pdf.

56 See, for example, Thomas O. McGarity, “CPR Perspective: Estimating Regulatory Costs,” Center for Progressive
Reform, at http://www.progressivereform.org/perspestimatingReg.cfm.

57 See, for example, Stuart Shapiro, “How Much Is That Regulation In the Window?”, The Hill, July 31, 2014, at
http://thehill.com/blogs/pundits-blog/2 13538-how-much-is-that indow, stating that “agencies have
clear motivations when it comes to making the assumptions that will determine their assessment of the cost of their
regulations. They don't want a regulation to appear too costly or they risk losing political support for the regulation.”

58 Winston Harrington, Richard D. Morganstern, and Peter Nelson, “On the Accuracy of Regulatory Cost Estimates,”
Journal of Policy Analysis and Management, vol. 19, no. 2 (Spring 2000), pp. 297-322.

5° Winston Harrington, Richard D. Morganstern, and Peter Nelson, “How Accurate Are Regulatory Cost Estimates?”
Resources for the Future, March 5, 2010.

§ Office of Management and Budget, Validating Regulatory Analysis: 2005 Report to Congress on the Benefits and
Costs of Federal Regulations | and Unfunded Mandates on State, Local, and Tribal Entities, available at
https:/Awww.whiteh v/sites/default/files/omb/: /omb/inforeg/2005_cb/final_2005_cb_report.pdf.

Congressional Research Service R44348 - VERSION 2 - UPDATED 12
711

Methods of Estimating the Total Cost of Federal Regulations

and compared them with ex post estimates, when they were available.“' OMB’s conclusions were
that the costs of regulations were more often overestimated by the agency, but that the benefits
were sometimes overestimated as well.

A primary reason observers have given for the overestimation of costs is that agencies tend to
underestimate industry’s ability to innovate, and therefore compliance with regulations
sometimes turns out to be less costly than expected. The ability to adapt to regulatory
requirements and identify more cost-effective methods of meeting compliance targets can result
in lower compliance costs than initially anticipated by the agency. For example, consider the
Environmental Protection Agency’s acid rain (sulfur dioxide) program in the 1990s. Mandated
under the Clean Air Act Amendments of 1990, the EPA issued regulations aimed at reducing
sulfur dioxide emissions. Studies suggest that the EPA’s initial cost estimates for these
regulations were too high due to EPA’s underestimation of how industry would adapt and find
less costly means of achieving the reduction targets. In sum, as stated in one retrospective study,
“When forecasting the costs of new environmental regulations, economic analysts have routinely
ignored a primary economic lesson: Markets will cut costs through innovation.”

A number of other reasons may contribute to inaccuracies in agency estimates of costs, For
example, delays in implementation of regulations can help lower the compliance costs as it can
allow industry more time to identify cost-effective solutions. Over- or under-estimating certain
effects of regulations can also result in inaccuracies, such as compliance rates among regulated
entities. Finally, agencies first estimate costs and benefits while writing the proposed regulation,
but the regulation may change in response to comments received during the public comment
period.™ As regulations are revised in response to comments, cost-benefit estimates are not
always updated. Changes made in the rule after it has been proposed and before it is finalized
could affect the likely costs and benefits of the rule—for example, if the final rule sets a standard
that is less stringent as compared to the proposed rule, it will probably be less costly to comply.

In short, the accuracy of the bottom-up approach relies heavily on the precision of the individual
cost and benefit estimates, but the accuracy of these estimates is likely to vary.

Measuring Costs over Time

Another issue in aggregating the costs and benefits of individual regulations is identification of
the appropriate time period. In other words, how many years’ worth of regulations should be
included in the total? Regulations issued many years ago typically still have some compliance
costs, although the cost of complying with regulations is generally thought to decrease over time.
For example, if compliance with a new regulation requires industry to invest in new types of
technology, once these investments have been made, the majority of the costs may already have
been incurred, and the ongoing costs will be less. The time frame under which these compliance
costs are distributed varies among rules. Similarly, the distribution of benefits can vary widely as

5! As mentioned above, ex post estimates of costs and benefits are not frequently conducted under current rulemaking
requirements or practice.

82 Gabriel Chan, Robert Stavins, Robert Stowe, and Richard Sweeney, “The SO2 Allowance Trading System and the
Clean Air Act Amendments of 1990: Reflections on Twenty Years of Policy Innovation,” Cambridge, Mass.: Harvard
Environmental Economics Program, January 2012, pp. 7-8, at http://www.hks. harvard.edu/m-rcbg/heep/papers/SO2-
Brief_digital_final.pdf. See also Eban Goodstein, The Trade-Off Myth: Fact and Fiction about Jobs and the
Environment (Washington, D.C.; Island Press, 1999), pp. 26-30.

6 See Winston Harrington, Richard D. Morganstern, and Peter Nelson, “On the Accuracy of Regulatory Cost
Estimates,” Journal of Policy Analysis and Management, vol. 19, no. 2 (Spring 2000), p. 310.

4 Agencies are gi lly required to accept public comments on proposed rules under the Administrative Procedure
Act (5 U.S.C. §553).

Congressional Research Service R44348 - VERSION 2 - UPDATED 13
712

Methods of Estimating the Total Cost of Federal Regulations

well, and benefits of regulations often are not realized until the regulation has been in place for
some time. For example, this is typically the case with regulations that have health benefits, such
as environmental regulations that are intended to improve air quality.

Individual cost estimates of regulations are calculated by comparing the anticipated effects of a
regulation against what would be expected to happen in a world without the regulation. These ex
ante estimates that are conducted prior to the issuance of the regulation are usually the sole source
of information on regulations’ costs. Under current requirements and practice, an ongoing
monitoring of the costs and benefits of rules is not required once a regulation has been issued.

The annual OMB reports have typically included 10 years’ worth of cost and benefit estimates.
According to the 2014 report, “OMB chose a ten-year period for aggregation because pre-
regulation estimates prepared for rules adopted more than ten years ago are of questionable
relevance today.””®> Similar reasons are cited in earlier versions of the OMB reports.

In its 2014 report, OMB acknowledges this weakness in its approach, stating that because the
estimates do not include non-major rules or rules issued more than 10 years ago, the total costs
and benefits currently in effect are like to be “significantly larger” than the totals in the report.
Over time, however, measuring the effects of those rules issued more than 10 years ago will
become increasingly difficult. As stated in a 2006 study that discussed OMB’s practice of
including 10 years’ worth of costs and benefits in its annual reports,

If the regulation only requires small changes in behavior over a small time interval, then
analysts feel confident of estimating the cost, hypothetical or not. But as the size or time
interval increases, the shadow of the hypothetical looms ever larger. To take an extreme
example, how would be begin to estimate the cost of federal child labor laws that were
enacted during the 1930s?

It is certainly the case that some rules that are more than 10 years old still impose a cost, and
therefore this 10-year rule may result in a lower estimate of total costs over time because it
excludes those rules. However, some cutoff probably should be made, as including estimates for
costs of regulations made more than 10 years ago becomes less practicable.

These potential flaws have led some to attempt to use an entirely different approach to estimating
the effects of regulations: the top-down method, which is discussed next.®*
“Top-Down” Method: Estimating Costs Using
Macroeconomic Modeling

Some scholars have adopted an approach to estimating the costs of rules that is referred to as a
top-down approach. This section explains and analyzes the top-down approach, using a case
study as an illustration for several of the concepts discussed.

6 2014 OMB Report, p. 9.
6 2014 OMB Report, p. 18.
§7 Winston Harrington, “Grading Estimates of the Benefits and Costs of Federal Regulation: A Review of Reviews,”

Resources for the Future Di ion Paper, September 2006.
$8 In the Crain and Crain report discussed in detail below, the authors state that “In summary, the constraints under
which OMB operates yield cost estimates for only a small proportion of regulati The hallenges lead

us to adopt techniques in this study that facilitate reasonable approximations of regulatory costs that have been omitted
in estimates by OMB and other studies” (pp. 5-6).

Congressional Research Service R44348 - VERSION 2 - UPDATED 14
713

Methods of Estimating the Total Cost of Federal Regulations

What Is the Top-Down Approach?

The top-down approach uses macroeconomic. variables and modeling techniques to measure the
effect of regulation on the economy as a whole. Rather than aggregating existing cost estimates,
the top-down method uses the results of an economic model that has been used to measure the
relationship between the size of an economy, or economic growth, and some proxy of the level of
regulation in a country, to measure the economic effects of regulation. This method typically
compares the U.S. economy, as measured by some variable such as gross domestic product
(GDP), to a hypothetical scenario in which the U.S. has less regulation. The approach takes the
difference in the GDP under these two scenarios—the status quo and the scenario with less
regulation—and calculates the change in GDP that might occur were the U.S. to reduce its overall
amount of regulation. This potential change in GDP is considered to be the cost of regulation
under the top-down approach and is explained in further detail below.

Why Use the Top-Down Approach?

The benefits of using a top-down approach, in many ways, are opposite from the bottom-up
approach described above. Because the top-down approach uses measurements of various
economic factors, it incorporates broader, more indirect effects that are not included in the
bottom-up approach. This could include indirect economic effects, as well as direct effects that
are not monetized.

Case Study: Crain and Crain Report

A commonly cited study using the top-down approach to totaling the cost of regulation is entitled
“The Cost of Federal Regulation to the U.S. Economy, Manufacturing and Small Business,” by
W. Mark Crain and Nicole V. Crain, and it was most recently released in September 2014.

The Crain and Crain report estimates the total cost of regulation and also explores the distribution
of those regulatory costs among regulated entities. The component of the report that is most
discussed in the debate over regulatory reform is the estimate of the total cost of regulation.”
Hence, this CRS report focuses primarily on the components of the studies that describe the total
cost of regulation, and not on the portion of the report exploring the distribution of costs among
different types of firms.”!

The Crain and Crain estimate of the total cost of regulation is not a purely top-down measure of
the cost of regulations. It combines a top-down estimate—their estimate of the cost of economic
regulation—with a bottom-up estimate of environmental, tax compliance, occupational safety,
and homeland security regulation. However, the estimate of the cost of economic regulation
resulting from their top-down methodology is almost 75% of the total estimate, totaling $1.439

69 W. Mark Crain and Nicole V. Crain, The Cost of. Federal Regulation to the U.S. Economy, Manufacturing and Small
Business, A Report for the National A ion of Mi September 10, 2014, at http://www.nam.org/
CostofRegulation/.

% See, for example, Cheryl Bolen, “Study Commissioned by NAM Finds Regulations Cost $2 Trillion,” BNA Daily
Report for Executives, September 10, 2014.

1 For example, earlier versions of the report written for the Small Business Administration’s Office of Advocacy
focused on the disproportionate cost of regulations on small businesses. The 2014 version, which was prepared for the
National Association of Manufa , intended to fill an “inf ion gap by quantifying the costs of regulatory
compliance on firms, particularly manufacturers in the United States, and to extend some of the previous efforts to
measure the aggregate regulatory costs.” Crain and Crain 2014, p. 1.

Congressional Research Service R44348 - VERSION 2 - UPDATED 18
714

Methods of Estimating the Total Cost of Federal Requlations

trillion out of $2.028 trillion in the 2014 study. This report only discusses that portion of their
estimate, as it is the most widely cited top-down study in the regulatory reform debate, and
therefore serves as a useful example for discussion.

Background on the Crain and Crain Report

The 2014 Crain and Crain report can be traced back to a report originally published in 1995 by
Thomas D. Hopkins for the Small Business Administration’s (SBA’s) Office of Advocacy
entitled “Profiles of Regulatory Costs.””* Each of the studies from 1995 through 2010 was
prepared for the Office of Advocacy.

In the 1995 study, Hopkins estimated annual federal regulatory costs to be in the range of $416
billion to $668 billion in 1995. Six years later, in 2001, W. Mark Crain and Hopkins issued a
follow-up to the 1995 Hopkins study, estimating the total annual cost of regulations to be $843
billion in 2000.” In 2005, Crain estimated annual regulatory costs to be about $1.1 trillion in
2004.” In 2010, Nicole V. Crain and W. Mark Crain issued another version of the study, which
estimated the total cost of regulation to be $1.75 trillion in 2008. They explained the increase
from $1.1 trillion in the 2005 report to $1.75 trillion as being, in part, the result of “new
methodological techniques,” meaning that “direct comparisons to the results in their prior studies
should be made with caution.””5

A number of concerns were raised about the methodology used in the 2010 report—and primarily
the methods used to arrive at the $1.75 trillion of the total cost of regulation. Some of the entities
raising concerns included the Office of Advocacy itself, the entity that had granted the contract
under which the study was conducted. For example, the Office of Advocacy posted a number of
caveats on its website where the report was linked, stating that “the findings of the study have
been taken out of context and certain theoretical estimates of costs have been presented publicly
as verifiable facts.””© A 2011 CRS report called into question the methods used in the report to
arrive at the total estimate of the cost of federal regulation.” A 2014 Government Accountability

” Thomas D. Hopkins, “Profiles in Regulatory Costs: Report to the U.S. Small Business Administration,” November
1995, available at http://www.sba.gov/sites/default/files/files/rs1995hoptot.pdf.

% The authors explained that “subseq gul yd develop and the availability of new data clarify and in some
cases amplify the basic 1995 findi latory b inue to climb, and to disadvantage small businesses.” W.
Mark Crain and Thomas D. Hopkins, “The Impact of Remkiony Costs on Small Firms: A Report for the Office of
Advocacy, U.S. Small Business Administration,” 2001, available at http://www.sba.gov/sites/default/files/files/
rs207tot.pdf.

74 Again, the increase over the earlier estimate appeared to be primarily due to a change in methodology from the 2005
report. W. Mark Crain, “The Impact of Regulatory Costs on Small Firms,” available at http://www.sba.gov/sites/
default/files/files/rs264tot.pdf.

78 Crain and Crain re-estimated the numbers for 2004—which were presented in the 2005 report—using the
methodology from the 2014 study. After the methodological adj the esti for 2005 i d by $445
billion to a total of $1.7 trillion, converted into 2009 dollars.

76 These included the following: “The study is a top- -down analysis of regulatory costs that uses certain assumptions to
estimate totals. The study is not a bottom-up p ig of the overall cost of regulations. The overall figure of
$1.75 trillion in costs is derived from a number of different ptions and to create an estimate. As with
almost any academic methodology, it was not intended to be considered a precise finding. The study demonstrated that
small businesses bear a larger burden from regulations than large busi It was not intended to do more than
provide an estimate of this disparity.” See https://www.sba.gov/adv y/imp: gulatory-costs-small-firms for these
and other caveats about the study.

7” CRS Report R41763, Analysis of an Estimate of the Total Costs of Federal Regulations, by Curtis W. Copeland. The
author of that report is no longer at CRS; congressional clients with questions about its can be dii d to the
author of this report, Maeve P. Carey.

Congressional Research Service R44348 - VERSION 2 - UPDATED 16
715

Methods of Estimating the Total Cost of Federal Requlations

Office (GAO) report also raised issues with the study related to federal data quality standards,
asserting that the Office of Advocacy failed to uphold those standards.”®

Summary of the 2014 Crain and Crain Report

The 2014 Crain and Crain study estimated the total cost of federal regulation to be $2.028 trillion
in 2012 (in 2014 dollars), an amount equal to 12% of U.S. GDP. This section summarizes the
methodology used to arrive at this estimate, so that the estimate may be used as an illustration
throughout the rest of the discussion of the top-down methodology.”®

As mentioned above, economic regulation is the majority of the total cost of the Crain and Crain
estimate: $1.448 trillion.®° According to Crain and Crain, economic regulations are those that
“govern decision-making in market transactions. These include markets for final goods and
services; markets for physical and human resources; credit markets; and markets for the transport
and delivery of products and factors of production.”*!

To arrive at this estimate of the total cost of economic regulation, Crain and Crain conducted a
cross-country comparison of 34 Organization for Economic Cooperation and Development

78 Specifically, GAO said that Advocacy did not retain the underlying information for the Crain and Crain study,
making it “much more difficult to assess the quality of that work, including its objectivity.” When GAO asked to speak
with Crain and Crain to ask them “a set of questions related to the criticisms of the methodologies, data, and models
used,” Crain and Crain “would not speak with us, stating that they were no longer contractually obligated to respond to
our requests for information.” U.S. Government Accountability Office, Small Business Administration: Office of
Advocacy Needs to Improve Controls over Research, Regulatory, and Workforce Planning Activities, GAQ-14-525,
July 2014, http://gao.gov/assets/670/665 104.pdf; see especially pp. 13-16.

9 The NAM study included other el not di d at length here because they were not part of the estimate of
the total cost of regulation and therefore are not the focus of this report. For ple, the study included a survey of
NAM members given over a period of two weeks in 2014 that reported a number of finings, including, for example, (1)
88% of respondents said that federal government regulations were a challenge that affected their businesses in the prior
year or that their businesses would face in the future; (2) 72% of respondents indicated that their organizations
employed outside advisers to ensure that their operations comply with federal rules—most of these advisers consisted
of attorneys, accountants, and consultants; and (3) 48% of manufacturing firms incurred operations and maintenance
expenses for capital equir and other ible items purchased to comply with federal government requirements
during the 12 months prior to the survey.

8 As previously described, the remaining $580 billion in the Crain and Crain estimate is due to the remaining three
Pp I safety and health and homeland security, and tax compliance regulation.

Because they u use the b up approach to esti each of these types of regulation, they are not discussed in this
report.
First, Crain and Crain arrive at a total estimate of the cost of environmental regulations using two sources: the OMB
annual report to Congress on the costs and benefits of regulations, and a study from 1991 by Hahn and Hird that
provides an estimate of the total costs of environmental regulations prior to 1988. See Robert W. Hahn and John A.
Hird, “The Costs and Benefits of Regulation: Review and Synthesis,” Yale Journal on Regulation, vol. 8, no. 1 (Winter
1991), pp. 233-278. Using these measures, they arrived at a total of $330 billion for environmental regulations, Second,
to measure the occupational safety and health and homeland security regulations, they added the regulations
promulgated by the Department of Homeland Security and the Occupational Safety and Health Administration (OSHA)
in the Department of Labor, plus some additional calculations to and include the effects of passenger delays
tied to Transportation Security Administration ing. Using these and calculations, they arrived at a total
of $92 billion for occupational safety and health and homeland security regulations. Third, Crain and Crain measure the
cost of compliance with the federal tax code. To do so, they relied on the number of hours required to comply with tax
requirements provided by the Internal Revenue Service. They multiplied that number of hours times an hourly wage
rate of individuals who would be preparing the tax paperwork—accountants and auditors for individuals and human

professionals for busi Using this method, they arrived at a total estimate of $159 billion for tax
compliance. It is not exactly clear what the calculations for these figures were, because Crain and Crain did not appear
to provide in their report the calculations or the hourly wages for these types of professionals.

5! Crain and Crain 2014, p. 28.

Congressional Research Service R44348 - VERSION 2 - UPDATED 17
716

Methods of Estimating the Total Cost of Federal Regulations

(OECD) countries, including the United States. Specifically, they looked at the relationship
between each country’s economy and a proxy measure of the amount of regulation in each
country over eight years. The data Crain and Crain used for this proxy measure were derived
from the World Economic Forum’s Global Competitiveness Report.

Crain and Crain used three components of the Global Competitiveness Index, a component of the
Global Competitiveness Report that measures various aspects of the institutions, policies, and
factors that determine a country’s level of productivity. These types of measures are sometimes
referred to as governance indicators. The report uses an “Executive Opinion Survey,” which
captures the opinions of business leaders around the world to construct a number of its indicators,
Crain and Crain selected three indicators, each of which was constructed using the survey, to
represent the amount of economic regulation in each country. The three indicators were

¢ burden of government regulation;
e efficiency of legal framework in challenging regulation; and
* regulation of securities exchanges.*

The survey respondents provided a value for each of these indicators ranging from one to seven.
As Crain and Crain explained in their report, “higher values correspond to improvements in
regulatory quality—that is, reductions in the regulatory burden on product, factor and credit
markets.”* To construct their measure for each country and each year, Crain and Crain used the
mean value of these three factors. The regulation index that Crain and Crain used combined these
three factors into a single measure for each of the countries in each of the years for which the data
were available—2006 to 2013.

Using the mean value for the 34 countries over their eight-year period, Crain and Crain estimated
a regression model in which they measured the effect of a number of variables—with their
primary variable of interest being the measure of regulatory quality—on GDP per capita. The
other variables, or “control” variables, were foreign trade as a share of GDP, population over 65
relative to population aged 19 to 65 (the “dependency ratio”), new capital investment as a share
of GDP, size of the labor force, and tax revenues as a share of GDP.

Based on the results of the regression model, Crain and Crain concluded that the effect of their
purported proxy of economic regulation on GDP per capita was statistically significant. Further,
they used the results of the regression model to estimate the total cost of the index on the GDP per
capita in the United States. To do so, they compared the U.S. score on the regulation index with
the average score of the five top performing (i.e., highest ranked) countries on the scale, which
they referred to as the “benchmark countries.” They used this “benchmark” measure as a
hypothetical measurement of what a lower level of regulation in the United States could be. The
difference between the U.S. score and the benchmark countries’ average score was 26%,

Crain and Crain concluded that this 26% difference in the regulation index in the United States
“implies an impact on GDP equal to $1.439 trillion. In other words, if the burden of economic

82 Klaus Schwab, World Economic Forum, The Global Competitiveness Report 2013-2014, Full Data Edition, Geneva,
2013, at http://reports. weforum.org/the-global-competitiveness-report-2013-2014/.

83 According to Crain and Crain, not all three variables had observations for every year in their sample. For the years
available, they used the average of the three Pp that were availabl

™ Crain and Crain 2014, p. 32.

85 Bach of these independent variables was lagged by one year. Crain and Crain also included tax revenues as a share of
GDP squared to allow for a nonlinear effect of tax policy. This choice of independent variables was different from
previous models they used, though they do not make clear why they chose different variables this time.

Congressional Research Service R44348 - VERSION 2 - UPDATED Oo 18
717

Methods of Estimating the Total Cost of Federal Regulations

regulation in the United States matched the benchmark countries, U.S. GDP would be $1.439
trillion higher than it was in 2012.” To the $1.439 trillion estimate, Crain and Crain added
another $8.3 billion, which was the estimated cost of import restrictions from the U.S.
International Trade Commission.*’ The total estimate of the cost of economic regulation they
arrived at using this methodology was $1.448 trillion.

Analysis of Top-Down Approach to Estimating Costs and Benefits

A number of issues have been raised with the top-down approach, some of which are explained
below using the Crain and Crain study as an illustration.

Importance of Accurate Measures of Regulation in Top-Down Approach

One challenge for the top-down approach to estimating the cost of regulation is that the accuracy
of the findings is dependent on the validity of the proxy measure of regulation. The proxy is used
to model the relationship between the size of the economy and amount of regulation, and then the
parameter estimates resulting from the model are used to calculate the total cost of economic
regulation.

Identifying an accurate measure of regulation, however, is a challenge. As explained in a report
by the Council on Foreign Relations (CFR) on federal rulemaking policy in the United States and
other countries, as well as in previous CRS reports, quantifying the total amount of regulation is
an inherently difficult task.** As stated in the CFR report,

Economists have not settled on a good way to measure overall regulatory burden ...
Because of these data limitations, the best empirical studies take on a specific regulation
rather than the full stock of regulations. Largely unknown is how the average business is
affected by the cumulative set of regulations, or whether certain regulations harm or help
different kinds of business activity, such as innovation or entrepreneurship.®?

Obtaining an accurate proxy measure of regulation is key in any economic model that uses
regulation as an explanatory variable, because an inaccurate measure can introduce serious
uncertainty into the model’s results. The term economists use to refer to whether a measure of a
construct correctly represents what it purports to represent is “content validity.” To illustrate the
importance of content validity in the top-down approach of measuring the cost of regulation, this
section will more closely examine the measure of “regulatory quality” used by Crain and Crain.

Crain and Crain referred to their measure of regulatory quality as the “Economic Regulation
Index.” They created the index from data from the World Economic Forum’s (WEF’s) annual
Global Competitiveness Report—specifically, the report’s Executive Opinion Survey.” In that
survey, the WEF captured the opinions of over 13,000 business leaders in 148 different
economies during a five-month period. Most of the survey questions, including the three used in

*6 Crain and Crain 2014, p. 33. This value appears to be adjusted to 2014 dollars.
87 Crain and Crain do not explain why they added the cost of import restrictions, It appears they may have added it

because they did not believe it would be captured in their of. B
88 Rebecca Strauss, Quality Control: Federal Regulation Policy, Council on Foreign Relations, Renewing American
Progress Report and Scorecard, New York, NY, March 2015, http://www.cft.org/corpo! ion/quality-control.

federal-regulation-policy/p36110?cid=oth-partner_site-Reg_Blog-Renewing_America_Regulation_Policy-031015; and
CRS Report R43056, Counting Regulations: An Overview of Rulemaking, Types of Federal Regulations, and Pages in
the Federal Register, by Maeve P. Carey.

8 Quality Control: Federal Regulation Policy, p. 3.
® For a more complete discussion of how Crain and Crain constructed this variable, see Appendix C of the 2014 report.

Congressional Research Service R44348 - VERSION 2 - UPDATED 19
718

Methods of Estimating the Total Cost of Federal Regulations

the Crain and Crain study to measure regulation, involved rating on a scale of one to seven a
particular aspect of the operating environment in the respondent’s country. The questions covered
such topics as innovation and technology infrastructure, education and human capital, and
tourism. To create a measure of regulation from this survey, Crain and Crain selected three
questions, each of which included an explicit reference to regulation (which appears to be how
they selected them): (1) burden of government regulation, (2) efficiency of legal framework in
challenging regulation, and (3) regulation of securities exchanges.

Are these three questions from the Executive Opinion Survey measuring this type of specific
regulation—in other words, can the responses to these three questions be considered a useful
proxy of the burden of economic regulation? This may be difficult to answer, but it is crucial to
the validity of the study’s conclusions. Crain and Crain state that “the reach of economic
regulations is vast. This means that an encompassing methodology is required to derive an
estimate of these costs.”®! While their statement about the vastness of economic regulation is
certainly true, whether their measurement and methodology measures it accurately is difficult to
validate,

Proxy measures of governance indicators are inherently imprecise, and they cannot be reliably
used to estimate macroeconomic outcomes. A recent article examining a similar cross-country set
of indicators illustrates the difficulty in identifying an accurate measure for certain inherently
abstract concepts related to governance, such as the “rule of law,” or, in this case, regulation.”
The article specifically focused on the World Bank’s “Worldwide Governance Indicators” (WGI),
though it argued that “the concerns raised here about the WGI apply equally to other current
governance indicators.”™ The article stated that “both researchers and policymakers should
require evidence that governance indicators are valid before employing them. In the absence of
such evidence, research results obtained using such indicators are uninterpretable and should not
survive peer review. For policymakers, reliance on such indicators would be arbitrary.” It could
be argued that the use of such indicators in the top-down model of total cost of regulation may
suffer from this problem of questionable measurement.

Specific concerns over this issue as it relates to top-down studies involving regulation were raised
in 2010 over the Crain and Crain report and arguably still apply to the 2014 report as well, due to
the similarities of their measures. For example, economist Art Kraay, one of the creators of the
World Bank’s Regulatory Quality Index, the measure of regulation that Crain and Crain used in
their 2010 study, commented in response to their study that the measure of regulatory quality they
created measured the perceptions of various regulatory environments, rather than the stringency
of those environments. The index used in the 2014 study uses a different proxy, although its

*' Crain and Crain 2014, p. 28.

% Furthermore, an incorrectly measured variable may cause some of the other estimates to be biased as well.

93M. A. Thomas, “What Do the Worldwide Governance Indicators Measure?” European Journal of Development

Research, vol. 22 (2010), p. 37, stating that “A proposed measure of a construct, an inherently abstract concept like the

‘rule of law’, is like a proxy measure in that it is a hypothesis about The hypothesis is that the proposed
correctly the construct. Like proposed proxy measures, not all proposed measurements of constructs

are equally valid.”

%4 The WGI were part of the 2010 Crain and Crain study, and, although they used a different measure in 2014, are

similar in construct to the 2014 measure described above. M. A. Thomas, “What Do the Worldwide Governance

Indicators Measure?” European Journal of Development Research, vol. 22 (2010), p. 47.

95M. A. Thomas, “What Do the Worldwide G Indi M ‘Y” European Journal of Development

Research, vol. 22 (2010), p. 51.

96 For a summary of Kraay’s comments, see CRS Report R41763, Analysis of an Estimate of the Total Costs of Federal

Regulations, by Curtis W. Copeland.

Congressional Research Service R44348 - VERSION 2 - UPDATED 20
719

Methods of Estimating the Total Cost of Federal Regulations

construction was similar—it measures business leaders’ perceptions of the regulatory
environment in various countries.*” Some research suggests that there may be key differences
between perceptions of something and actual levels of it, however:

There is a substantial difference between measuring a thing and measuring perceptions of
it. In the context of governance, for example, perceptions of crime risk have been shown
to be quite different than actual crime levels (see, for example, Forgas, 1980; Pfeiffer,
2005); perceptions of corruption have been shown to differ from actual corruption levels
(see, for example, Olken, 2006; Seligson, 2006); and trust in government has been shown
to differ from administrative performance (Van de Walle and Bouckaert, 2007).

In sum, this question of whether a measurement based on survey responses of business leaders or
other individuals, such as the Executive Opinion Survey, is measuring what it purports to
measure, is an important one. With any top-down model of the economic effects of regulation, the
validity of a proxy for regulation is essential—and measuring an inherently abstract concept like
the stringency of regulation in a country is difficult. Without a valid proxy, which is difficult to
identify for the reasons discussed above (and possibly others), the findings of any top-down study
could be brought into question.

Questions About Proper Model Specification

Setting aside the question of how to undertake the difficult task of measuring regulation, and
assuming that the measure of regulation is a valid measurement, another crucial question remains
for the top-down approach to measuring the cost of regulation: how should one select the right
model?

In a regression model, such as the one used by Crain and Crain, a researcher is attempting to
explain a relationship between variables by analyzing the extent to which the dependent variable
can be explained by changes in the independent variables. Proper selection of all variables in the
model is important, as discussed below.

Selecting Independent Variables

Selecting and including the proper independent and control variables in an econometric analysis
is crucial to the validity of the model’s results. For example, a researcher must include all
variables that are thought to be theoretically relevant and take care not to omit variables that may
help explain the outcome.” Explaining and theoretically justifying the components of economic

97 Crain and Crain did not explain why they used this different index as their main indicator in the 2014 study. They
did, however, use the World Bank measurement that they had used in 2010 as an alternative proxy for the amount of
lation. The lusions they hed with this alternative measurement were similar; see p. 71.
ad M. A. Thomas, “What Do the Worldwide Governance Indicators Measure?” European Journal of Development
Research, vol. 22 (2010), p. 36. Referenced articles include Joseph P. Forgas, “Images of Crime: A Multidimensional
Analysis of Individual Differences in Crime Perception,” /nternational Journal of Psychology, vol. 15, no. 1 (1980),
pp. 287-299; Christian Pfeiffer, Michael Windzio, and Matthias Kleimann, “Media Use and its Impacts on Crime
Perception, Sentencing Attitudes and Crime Policy,” European Journal of Criminology, vol. 2, no. 3 (July 2005), pp.
259-285; Benjamin A. Olken, “Corruption Perceptions vs. Corruption Reality,” NBER Working Paper No. 12428,
2006; Mitchell A. Selig “The M and Impact of Corruption Victimization: Survey Evidence from Latin
America,” World Development, vol. 34, no. 2 (2006), pp. 381-404; and Steven Van de Walle and Geert Bouckaert,
“Perceptions of Productivity and Performance in Europe and the United States,” /nternational Journal of Public
Administration, vol. 30, no. 11 (2007), pp. 1123-1140.
99 See A.H. Studenmund, Using Econometrics: A Practical Guide, 6* ed. (New York: Addison-Wesley, 2011), P. 167,
stating that “the primary id ind an independent variable belongs in an eq is
the variable is essential to the regression on the basis of theory.”

Congressional Research Service R44348 - VERSION 2 - UPDATED 21
720

Methods of Estimating the Total Cost of Federal Regulations

models, including all independent variables, is important: “It is critical that researchers explain
and justify the assumptions that underlie their model, which are presumed to be informed by

Failure to include all relevant variables in an economic model can result in omitted variable bias.
Omitted variable bias can occur when one of the explanatory variables—those variables in the
model that are helping to explain changes in the dependent variable—has its effects overstated
because a variable that is related to that variable has been left out of the model. In other words,
the omitted variable’s explanatory power will be attributed to the variable that is included in the
model, as long as the two variables are correlated. As explained in one study,

Because top-down methods [of estimating the cost of regulation] associate indicators of
regulatory activity with changes in macroeconomic variables, they risk attributing to
regulation the effects of other variables that are not considered in the analysis but that may
be correlated with regulatory activity. There is a strong chance of omitted variable bias, in

In sum, were a top-down model of regulation to leave out some relevant variables, the effect of
regulation could be overstated.

Selecting a Dependent Variable

Furthermore, identifying a theoretically sound dependent variable is crucial to the validity of a
model’s results. Crain and Crain used GDP per capita as their dependent variable, rather than
GDP growth rate. Measuring GDP per capita does provide an indication of the size of a country” s
economy. However, it can potentially be problematic because it ignores the historical
circumstances that have led each country’s economy to its current size, and therefore it presumes
to explain the current size of each economy only based upon the factors in the model. Using the
rate of GDP growth instead of GDP per capita would presume that the changes in the size of each
country’s economy are explained by the independent variables, not the actual size of the economy
itself—which could be considered more likely.

Selecting the Correct Form

Another important issue related to model specification is whether the nature of the relationship
between the dependent variable and the independent variables is properly specified: in other
words, is the relationship linear or nonlinear? A linear relationship in expressed on a graph with a
straight line and assumes that the rate of change in the dependent variable does not vary—hence
the straight line on a graph. A non-linear relationship can also be expressed on a graph but does
not have a straight line, and it assumes that the rate of change in the dependent variable can
change. These concepts are discussed more below in the context of the top-down approach.
Notably, however, identifying the form of the relationship between dependent and independent
variables is important—“the consequences of an incorrect functional form for interpretation and
forecasting can be severe,”!

100M. A. Thomas, “What Do the Worldwide Governance Indicators Measure?” European Journal of Development
Research, vol, 22 (2010), p. 41.

10! Winston Harrington, “Grading Estimates of the Benefits and Costs of Federal Regulation: A Review of Reviews,”
Resources for the Future Di ion Paper, September 2006, p. 12.

102 AH. Studi d, Using Ec ics: A Practical Guide, 6° ed. (New York: Addison-Wesley, 2011), p. 207.

Congressional Research Service R44348 - VERSION 2 - UPDATED 22
721

Methods of Estimating the Total Cost of Federal Regulations

Crain and Crain ran a linear regression, which is based upon the assumption that the relationship
is of direct proportionality and is expressed on a graph with a straight line.'"? Whether this is the
type of relationship between regulation and size of a country’s economy, or its economic growth
generally, is an important question. Crain and Crain did not appear to provide a theoretical basis
for assuming the relationship is linear, and some scholars have suggested that the relationship
between regulation and economic growth is nonlinear. A 2012 working paper from the George
Washington University Regulatory Studies Center suggested that “perhaps... up to a point,
increasing the size of government may tend to increase GDP, but that the relationship reverses
after a certain threshold.”!* That paper examined whether a measure of the on-budget costs of
federal regulation in the United States had an effect on GDP growth, which is a different
objective than a top-down model of the cost of regulation, but it illustrates the important point
that some effects on GDP can be nonlinear. If such model misspecification did occur in the Crain
and Crain model, the results of their model could be held in question.

In sum, these three issues related to model specification—selection of independent variables,
selection of dependent variables, and selection of the correct functional form for the model—are
highly important to the reliability and validity of conclusions made based upon a top-down
estimate of the cost of regulation.

Other Potential Methodological Issues

There are several additional methodological issues that may be of concern in the top-down
approach, including unclear directions of causality and insufficient sample size in the model.

Questions of Causality

The first issue, which is linked to the question of identification of a dependent variable, relates to
questions of causality in a top-down approach that uses a measure of regulation to explain the
health of a country’s economy: does the amount of regulation affect the economy, or could the
economy also have an effect on the amount of regulation? This uncertainty about the direction of
the causality between different components of a model is referred to by economists as
“endogeneity.” The presence of endogeneity can cause bias in the parameter estimates resulting
from the model. As mentioned earlier in this report, it is crucial that researchers using a top-down
approach explain the theory behind all of the components of their models. Having a solid
theoretical foundation related to the causality question can reduce or eliminate the likelihood that
a model will suffer from endogeneity.

In the case of top-down studies of regulation like Crain and Crain, the parameter estimates are
used to calculate the potential difference in GDP, which is the estimate that Crain and Crain
provide for the cost of economic regulation. As explained in the section above summarizing their
methodology, Crain and Crain assert that the GDP per capita is a direction function of the amount

1083 There may be additional econometric issues with the linear regression that are beyond the scope of this report, For
linear regressi dels rely on several other ptions that are not di d here; for a more detailed

di ion of these iP , see Jeffrey M. Wooldridge, introductory Econometrics: A Modern Approach, 5" ed.

(South-Western - Cengage Learning, 2012).

104 Tara M. Sinclair and Kathryn Vesey, Regulations, Jobs, and Economic Growth: An Empirical Analysis, George

Washington University Regulatory Studies Center, Working Paper, Washington, DC, March 2012, p. 27,

http://reg: bian.gwu.edu/files/downloads/032212_sinclair_vesey_reg_jobs_growth.pdf. That paper
examined whether there was a relationship between changes in the on-budget costs of federal regulation in the United
States and and it luded that “we found basically no evidence that the regulators’ budget

has anything other than a zero effect on GDP and employment.”

Congressional Research Service R44348 - VERSION 2- UPDATED 23
722

Methods of Estimating the Total Cost of Federal Regulations

of regulation in a country. They do not explore the possibility that the causality could also go in
the other direction, The presence of such endogeneity can cause the results of the model to be
incorrect.

The issue of correctly identifying the causal relationship is a challenge for scholars examining the
relationship between regulation and other macroeconomic factors. For example, a recent study of
the “regulatory volume” in states across the United States “looked at the relationship between
regulatory output and a series of indicators described above meant to represent the economic
health of the state.” The study concluded that “citizens in more prosperous states may very well
demand more regulation than citizens in less prosperous states.”!°A similar concern could
potentially be raised about the direction of causality between the volume of regulation and the
economy.

Sample Size

The second is an issue of sample size, particularly for a top-down study that uses a cross-country
comparison of industrialized economies. A small sample size can have detrimental effects on the
precision of the model’s results: a smaller sample size makes the estimate less precise and
therefore less reliable. Researchers who examine cross-country comparisons of regulation face
some potential problems, including the small number of fully industrialized countries and the
fairly short length of time over which regulatory measures have been constructed.

The Crain and Crain study uses 34 countries and a time period of eight years: 2006 to 2013. This
is a relatively small sample size, especially given that the measures of regulation and other
variables in the model are unlikely to change very much from one year to the next in just an
eight-year period.! In addition, this specific eight-year period is not necessarily a typical one, as
it is the period leading up to and immediately following the Great Recession.!”’ Therefore,
conclusions made based upon this narrow time period may not be generalizable to other years or

Potential for Double-Counting Costs

In the top-down approach, another potential problem is whether costs may be double-counted.
Crain and Crain separate their total estimate of the cost of regulations into four categories, as
described above, although it appears that this approach may be double-counting the cost of some
regulations for at least two reasons. :

The first reason is an econometric one: as mentioned above, the potential for omitted variable bias
exists in any econometric model. If Crain and Crain omitted a variable that is highly correlated
with their measure of “economic” regulations—such as a measure of environmental or other
types of regulations, which are almost undoubtedly correlated with their measure of economic
regulation—then the explanatory power of the omitted variable becomes attributed to the
coefficient on the economic regulation measure. In other words, the explanatory strength of that

195 Stuart Shapiro and Debra Borie-Holtz, The Politics of Regulatory Reform (New York: Taylor & Francis, 2013), pp.
65-66.

106 The R-squared in the table for “within” the countries in their sample is .01, meaning that their model is not a very
good fit to explain the changes within countries over that period.

'07 Crain and Crain included dummy variables for two years, 2008 and 2009, but did not explain why.

108 The Crain and Crain data appear to have other issues related to sample size as well. For example, their sample
appears to be missing some observati 34 countries times eight years should yield 272 observations, but they report
their number of observations in Table 3 to be 219. They do not provide an explanation for why these observations are
missing.

Congressional Research Service R44348 - VERSION 2: UPDATED 24
723

Methods of Estimating the Total Cost of Federal Regulations

measure is inflated by the omission of other variables that are not included. By adding other
measures of regulation, including environmental regulations, to the total cost they estimate for
economic regulation, Crain and Crain may therefore be double-counting the effects of these other
types of regulations.

Second, the potential for double-counting exists because of the nature of the questions asked to
business leaders that comprise the regulatory quality measure. The questions themselves do not
necessarily measure only economic regulation, although Crain and Crain imply that to be the
case. Rather, as discussed above, they measure potentially very broad effects of all types of
regulation by measuring the overall regulatory environment. Because Crain and Crain is a hybrid
study that also employs a bottom-up methodology to measure certain types of regulation, they
add an estimate of the cost of other types of regulation to their estimate of the cost of economic
regulation. As a result, their overall number of roughly $2 trillion could include some double

No Discussion of Benefits of Regulations

To date, it appears that the top-down approach has not been used to estimate benefits of
regulation—only costs, It is not clear whether the method could be used to measure benefits,
because the approach measures cost in terms of potential economic growth that has not occurred
due to the amount of regulation. A parallel approach does not seem to be applicable to benefits,
which, as discussed above, are often not easily measured in dollar amounts or economic effects,
and therefore may not be able to be estimated in this same way.

Although the top-down method does not appear to be intended to measure costs and benefits,
having an estimate of costs without an estimate of benefits does not provide the complete context
for evaluating whether a country’s amount of regulation is appropriate. Such a comparison of
costs against benefits has been institutionalized in the regulatory process in the United States
since the early 1980s. Specifically, one of the underlying components of the current regulatory
system, which was formally put into place by President Ronald Reagan in 1981 when he issued
Executive Order 12291, is that agencies should consider the costs of individual regulations and
compare them against the benefits, and that “regulatory action shall not be undertaken unless the
potential benefits to society for the regulation outweigh the potential costs to society.”!!° This
general approach of comparing costs against benefits has been upheld since the Reagan
Administration formalized it in 1981, and the shift to become more reliant on estimates of costs
and benefits in informing regulatory decisions over the past several decades has been well

199 Furthermore, it is worth noting that the portion of their model that covers the i lati $580
billion—-may contain some of the same potential problems as those identified above for other bottom-up estimates.
0 Executive Order 12291, “Federal Regulation,” 46 Federal Register 13193, February 17, 1981, § 2(b).

President William Clinton maintained this general principle of weighing costs against benefits when he issued his
executive order on rulemaking, which replaced Executive Order 12291. Executive Order 12866 § 16). In his
executive order, President Clinton arguably took a slightly more lenient approach by ch the ig to requii
that the benefits to society justify the costs of the regulation, rather than outweigh.

President Barack Obama continued to uphold the practice of comparing costs against benefits when he issued
Executive Order 13563 in 2011, emphasizing, among other things, that agencies must “propose or adopt a regulation
only upon a reasoned determination that its benefits justify its costs (recognizing that some benefits and costs are
difficult to quantify).” Executive Order 13563 § 1(b).

‘lM See CRS Report R41974, Cost-Benefit and Other Analysi: Requirements int iz Process, dinated by
Maeve P. Carey, and CRS Report RL32240, The Federal Rulemaking Process: An Ovevien coordinated by Maeve P.

Congressional Research Service R44348 - VERSION 2 - UPDATED 25
724

Methods of Estimating the Total Cost of Federal Requiations

In sum, the notion that costs and benefits must be compared to one another has remained a crucial
component of the regulatory process in the United States over the past several decades. Under
current rulemaking requirements, agencies are responsible for measuring costs against benefits in
individual regulations, and because of the nature of the bottom-up method and its reliance on
those estimates, it can be used to make overall comparisons between total costs and benefits.
Such a comparison does not seem possible, however, at the macroeconomic level.

Summary: Advantages and Disadvantages of Two
Approaches

Each of the two main approaches taken to estimate the total costs and benefits of regulations have
pros and cons, which tend to mirror one another. This final section briefly compares the two
approaches and provides some perspective on why this issue is of potential interest to Congress.

The bottom-up approach to estimating the total costs and benefits of regulations, such as the
approach taken by OMB in its annual report to Congress, has several advantages. The bottom-up
approach involves adding up actual cost estimates calculated by agencies pursuant to rulemaking
requirements. These estimates are conducted on an individual basis for certain regulations, and,
although they often contain some uncertainty, are based upon specialized information the agency
has regarding expected costs and benefits.

Notably, current requirements for agencies to estimate costs and benefits of their rules are
intended to assist with agency decisionmaking in individual regulations by more fully informing
decisionmakers of the likely outcomes and providing a means of evaluating and comparing
regulatory alternatives. The potential utility of that information when taken out of the context of
individual rules and aggregated, however, is greatly reduced.

An individual cost-benefit analysis conducted by an agency and included in the bottom-up
aggregated estimate could also suffer from econometric problems similar to those described
above in the context of the top-down approach. However, the individual estimates used in the
bottom-up approach can be validated by comparing the ex ante estimates of costs and benefits to
ex post estimates. Some such studies exist and are discussed above. In addition, agencies may—
though they are not explicitly required to—revisit the original cost-benefit estimate when
conducting a retrospective review of their regulations.''” This provides a potential means of
validating the results of the bottom-up method, whereas the top-down method does not have a
similar opportunity for ex post validation.

The biggest potential problem with the bottom-up approach, however, is thatthe aggregated
estimate is unlikely to represent the costs and benefits of all rules. Not all rules are included in the
aggregate, because cost-benefit estimates are not currently conducted or required for all
regulations. Furthermore, even for rules in which a cost-benefit analysis is required, monetizing

Carey, and Eric A. Posner, “Controlling Agencies with Cost-Benefit Analysis: A Positive Political Theory
Perspective,” University of Chicago Law Review, vol. 68, no. 4 (Fall 2001), pp. 1137-1199, describing the
“entrenchment of cost-benefit analysis in American government” in recent decades ( pp. 1139-1140).

2A government-wide retrospective review is currently required under the Obama Administration, and similar reviews
have been required by previous administrations. It is unclear, however, the extent to which agencies re-examine or
recalculate their ex ante cost-benefit esti For more inf ion on the current retrospective review initiative
under the Obama Administration, see Joseph E. Aldy, Learning from Experience: An Assessment of the Retrospective
Reviews of Agency Rules and the Evidence for Improving the Design and Impl ion of Regulatory Policy, report
prepared for the consideration of the Administrative Conference of the United States, November 17, 2014, at

http://www. hks. harvard.edu/fs/jaldy/img/aldy_retrospective.pdf.

Congressional Research Service R44348 - VERSION 2-UPDATED 26
725

Methods of Estimating the Total Cost of Federal Regulations

certain types of costs and benefits can be challenging, and any effects of regulations that are not
monetized are not able to be included in a bottom-up aggregate.

Because of these limitations about what may be missing from the bottom-up estimate, a top-down
approach may be more likely to capture fully the overall cost of regulations, as the top-down
approach could conceivably provide a way to include in its estimate of indirect costs and effects
of regulations that are not included in the bottom-up approach. However, the top-down approach
has several potential problems when it comes to implementation, most of which are conceptual
and methodological. Any estimates of the cost of regulation resulting from a top-down approach
are entirely reliant on the validity of the model, identification of its components and structure, and
the theory behind it. The validity of an estimate is especially reliant upon the validity of the proxy
measure of regulation. In practice, overcoming these conceptual and methodological hurdles is
difficult, if not impossible, meaning that the results of a top-down approach should be treated
with a great deal of caution.

Finally, the top-down approach does not make a comparison of costs to benefits. Such a
comparison appears to be outside the purpose of the top-down approach, but having both
estimates of costs and benefits can provide a more complete representation of the cost-
effectiveness of a country’s regulation.

Issues for Congress

Because of the role Congress plays in delegating legislative authority to federal agencies to issue
regulations, Congress has shown an interest in conducting oversight of those regulations, both for
individual regulations and the regulatory system generally. One way for Congress to conduct
oversight of the regulatory system as a whole is to monitor the total cost and benefits of federal
regulation.

Inaccuracies in cost-benefit estimates conducted by agencies could have the effect of
undermining public confidence in the regulatory process.''> So, too, could a misunderstanding or
over-reliance on estimates of the total cost of regulation that are not intended to be considered
precise findings. For the reasons discussed throughout this report, both approaches to estimating
the total cost of regulation have inherent—and potentially insurmountable—flaws. The true cost
of regulation is incredibly difficult to estimate for the many reasons discussed in this report, and
perhaps others as well. The discrepancy between the two approaches and their associated
estimates raises the question of the utility of using such figures in the regulatory reform debate.

Author Information

Maeve P. Carey
Analyst in Government Organization and
Management

"3 Winston Harrington, Richard D. Morganstern, and Peter Nelson, “On the A y of Regulatory Cost Esti ”
Journal of Policy Analysis and Management, vol. 19, no. 2 (Spring 2000), p. 298.

Congressional Research Service R44348 - VERSION 2 - UPDATED 27
726

Methods of Estimating the Total Cost of Federal Regulations

Disclaimer

This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan
shared staff to congressional committees and Members of Congress. It operates solely at the behest of and
under the direction of Congress. Information in a CRS Report should not be relied upon for purposes other
than public understanding of information that has been provided by CRS to Members of Congress in
connection with CRS’s institutional role. CRS Reports, as a work of the United States Government, are not
subject to copyright protection in the United States. Any CRS Report may be reproduced and distributed in
its entirety without permission from CRS. However, as a CRS Report may include copyrighted images or
material from a third party, you may need to obtain the permission of the copyright holder if you wish to
copy or otherwise use copyrighted material.

Congressional Research Service R44348 - VERSION 2 - UPDATED 28
727

United States Government Accountability Office

GAO

Report to the Chairman, Subcommittee
on Financial Services and General
Government, Committee on
Appropriations, United States Senate

July 2014

SMALL BUSINESS
ADMINISTRATION

Office of Advocacy

Needs to Improve
Controls over
Research, Regulatory,
and Workforce
Planning Activities

GAO-14-525
728

July 2074

SMALL BUSINESS ADMINISTRATION

Office of Advocacy Needs to Improve Controls over
Research, Regulatory, and Workforce Planning
Activities

What GAO Found

The Office of Advocacy (Advocacy) within the Small Business Administration
(SBA) fulfills its mission by researching small business issues and providing input
into federal rulemaking and related regulatory activities. However, GAO identified
key areas in Advocacy's system of internal control that could be improved.

* Research. GAO found that Advocacy did not ensure that its staff
monitored the quality of the information the office disseminated, as
required. GAO reviewed 20 selected research products and found that in
416 cases a required quality review had not been documented. Advocacy
recently established a review policy for its research, but it does not
include procedures for selecting the reviewers or documenting that a
review occurred and how reviewer comments are addressed. GAO also
found that Advocacy staff had not followed federal information quality
guidelines to retain data and could not substantiate the quality of
information in two cost-estimation reports—a research product it has
contracted for every 5 years. Without better controls over its quality
review process and efforts to substantiate the information it
disseminates, Advocacy cannot ensure the validity of one of its core
activities—research in support of small businesses.

* Regulatory activities. Advocacy recently updated procedures for its
regulatory activities, but these could be strengthened. GAO found the
extent to which individual staff maintained records varied, in part,
because the procedures lacked policies for documentation. For instance,
the procedures state that when staff decide to intervene in the
rulemaking process, they must follow up as appropriate with the
interested groups to ensure that Advocacy has sufficient information and
data to support its case. However, there is no policy that these
interactions be documented. Federal internal contro! standards state that
documentation and records should be maintained. If key procedures are
not being documented, managers do not have an institutional record that
agency goals and objectives in this area are being met. GAO also found
that the Federal Advisory Committee Act's transparency and other
requirements do not apply to Advocacy's meetings with stakeholders to
get input on regulations (roundtables).

« Workforce planning. Advocacy's workforce efforts include training and
mentoring for new staff, but do not include succession planning, which is
recommended by the Office of Personnel Management. According to
federal internal contro! standards, effective management of a workforce
is essential to achieving program results. Officials told GAO that
Advocacy was a small office and that additional staff were hired on an
as-needed basis. However, some key staff have been with Advocacy for
many years and their experience will be difficult to replace. If Advocacy
does not incorporate succession planning strategies into its workforce
planning efforts, it is at risk of not having the skills and expertise to meet
its mission when key staff leave or retire.

United States A Office
729

Contents

Letter
Background 4
Advocacy’s Internal Controls Do Not Ensure the Quality of Its
Research and That Required Information Quality Practices Are
Followed 10
Documentation of Key Regulatory Activities is Inconsistent and
Roundtables Are Not Publicized According to Advocacy's
Policies 17
Advocacy’s Workforce Planning Efforts Lack Succession Planning 21
Conclusions 23
Recommendations for Executive Action 24
Agency Comments 25
Appendix | Objectives, Scope, and Methodology 27
Appendix I! Comments from the Office of Advocacy, Small Business
Administration 32
Appendix Il! Legal Analysis of the Applicability of the Federal Advisory Committee
Act to the Office of Advocacy’s Roundtables 34
Tables
Table 1: Advocacy Comment Letters by Policy Area, Fiscal Years
2009-2013
Table 2: Number of Roundtables by Policy Area, Fiscal Years
2009-2013 9
Figures

Figure 1: Office of Advocacy Organizational Chart, Fiscal Year

2014 6
Figure 2: Office of Advocacy Organizational Chart, Fiscal Year
2014 21

Pagei GAO-14-525 Office of Advocacy
730

Abbreviations

ADA Americans with Disabilities Act

AAPS Association of American Physicians and Surgeons

APA Administrative Procedure Act

BATF Bureau of Alcohol, Tobacco, and Firearms

CFPB Consumer Financial Protection Bureau

EPA Environmental Protection Agency

FACA Federal Advisory Committee Act

FOIA Freedom of Information Act

GSA General Services Administration

HCAAF Human Capital Assessment and Accountability Framework

HEW Department of Health, Education, and Welfare

JAG Judge Advocate General of the Army

OIRA Office of Information and Regulatory Affairs

OMB Office of Management and Budget

OPM Office of Personnel Management

OSHA Occupational Safety and Health Administration

OST Executive Office of the President's Office of Science and
Technology

RFA Regulatory Flexibility Act

SBA Small Business Administration

SBREFA Small Business Regulatory Enforcement Fairness Act of

1996

This is a work of the U.S. government and is. not subject to copyright protection in the
United States. The published product may be reproduced. and distributed in its entirety
without further permission from GAO. However, because this work may contain
copyrighted images or other material, permission from the copyright holder may be
necessary if you wish to reproduce this material separately.

Page ji

GAO-14-625 Office of Advocacy
731

U.S. GOVERNMENT ACCOUNTABILITY OFFICE

441 G St. N.W.
Washington, DC 20648

July 22, 2014

The Honorable Tom Udall

Chairman

Subcommittee on Financial Services and General Government
Committee on Appropriations

United States Senate

Dear Senator Udall:

Congress created the Office of Advocacy (Advocacy) within the Smail
Business Administration (SBA) in 1976 as an independent voice for small
businesses within the federal government.' The Chief Counsel for
Advocacy, appointed by the President and confirmed by the U.S. Senate,
directs the office and is tasked with representing the views and interests
of small businesses to other federal agencies, including during
rulemaking and related regulatory activities. Advocacy’s mission is to
encourage the development and growth of America’s small businesses by

* producing research to keep policymakers and other stakeholders
informed about the impact of federal regulatory burdens on small
businesses, document the role of small businesses in the economy,
and explore and explain issues of concern to the small business
community;

« intervening early in federal agencies’ regulatory development process
on proposals that affect small businesses and providing training in
complying with the Regulatory Flexibility Act (RFA) to agency
policymakers and regulatory development officials; and

« fostering two-way communication between federal agencies and the
small business community.

Questions have recently been raised about Advocacy’s efforts to
represent small businesses. For example, some stakeholders questioned
how Advocacy staff gather and use information to develop comment
letters on proposed regulations and whether that information actually
conveys the views of small businesses. Also, some parties have
expressed concerns that Advocacy’s information-gathering events
(“roundtables”) are not fully ttansparent and open to the public, and

‘PR. L. No. 94-305, §201, 90 Stat. 668 (1976).

Page 4 GAQ-14-525 Office of Advocacy
732

others have criticized the methodology of some of the research
conducted by contractors hired by Advocacy.

You asked us to review the Office of Advocacy. This report examines
Advocacy’s (1) research activities; (2) regulatory activities, including the
applicability of the Federal Advisory Committee Act’s (FACA)
transparency and other requirements to Advocacy’s roundtables; and (3)
workforce planning efforts.

To understand Advocacy's mission, operations, and participation in the
tulemaking process, we interviewed Advocacy officials, and reviewed
Advocacy documents, including its policies and procedures, budget and
strategic planning documents, annual reports to Congress on the RFA,
and other publications. To evaluate Advocacy’s research activities, we
selected a nonprobability sample of 20 of its products and assessed them
against Advocacy’s review process for its research (“peer review’), the
Office of Management and Budget’s (OMB) Peer Review guidance, and
OMB and SBA’s Information Quality Guidelines.? Our sample was
designed to include a variety of topics and report types and focused on
more recent publications in order to maximize the possibility that the
research staff involved would be available for interviews. In addition, we
evaluated three of Advocacy’s most recent external studies on the
economic costs of regulation and assessed the studies against OMB and
SBA Information Quality Guidelines. We also reviewed peer reviewers’
comments and other external reviews on the studies to understand
questions that had been raised about the studies. Lastly, we interviewed
the Advocacy officials responsible for this research to obtain information
on the steps taken to substantiate the quality of these studies.

2OMB, Final Information Quality Bulletin for Peer Review, December 16, 2004, This

Bulletin aimed at 9 the practice of peer
review of government science documents. OMe idelines for ing and it
the Quality, Objectivity, Utility, and Integrity of ion Dis it d by Federal

Agencies. 67 Fed. Reg. 8452 (Feb. 22, 2002). OMB’s information quality guidelines.
implement section 515 of the Treasury and General Government Appropriations Act for
Fiscal Year 2001 (P. L. No. 106-554). Section 515 directed OMB to issue government-
wide guidelines that "provide policy and p i to Federal ies for
ensuring and maximizing the quality, objectivity, utility, and integrity of information

by Federal agencies.” Agencies were
required to issue their own implementing guidelives by October 1, 2002. For SBA's
guidelines, accessed April 24, 2014, see http: JN sba. goviabout-

quality_guid

s. Advocacy officials told us s they follow SBA’s information quality guidelines.

Page 2 GAO-14-525 Office of Advocacy
733

To evaluate Advocacy's regulatory activities, we analyzed comment
letters and information-gathering events (roundtables) from fiscal years
2009 through 2013 as well as relevant policies and procedures. We
interviewed Advocacy staff who were responsible for these activities and
reviewed supporting documentation to understand their origins and
purposes. In addition, we attended three roundtables. To analyze whether
FACA (5 U.S.C. App. I) applies to Advocacy’s roundtables, we reviewed
relevant statutes, case law, regulations, and guidance. We also
considered Advocacy’s views on the issue. Lastly, we interviewed officials
from the entities that interact with Advocacy in rulemaking—the
Environmental Protection Agency (EPA), Occupational Safety and Health
Administration (OSHA), Bureau of Consumer Financial Protection, also
known as the Consumer Financial Protection Bureau (CFPB), and OMB’s
Office of Information and Regulatory Affairs (OIRA). Also, we interviewed
Officials from six industry associations that represent small and large
businesses; one large corporation; and two nonprofit organizations whose
missions relate to policies or rules under consideration, to understand
their perspectives on Advocacy's roundtables and other work. We made
our selections to include representatives from a variety of sources, and
while the results from our interviews cannot be projected to all entities
that interact with Advocacy, the information we gathered provides insights
into how the selected groups view Advocacy and its work in representing
small businesses to federal policymakers.

To assess Advocacy's workforce planning efforts, we interviewed senior
management to discuss any workforce planning efforts that were in place.
We evaluated those efforts and any related documents against applicable
federal standards for internal control and the Office of Personnel
Management's Human Capital Assessment and Accountability
Framework (HCAAF).° :

We conducted this performance audit from August 2013 to July 2014 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that

SHuman R in Agencies, HCAAF and HCAAF Systems, Standards,
and Metrics, 73 Fed. Reg. 23012 (Apr. 28, 2008).

Page 3 GAO-14-525 Office of Advocacy
734

the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.

Background

Under legislation that established Advocacy in its current form in 1976,
Advocacy’ duties are to

« serve as a focal point for small businesses’ concerns about the
federal government's policies and activities;

« advise small businesses on how to interact with the federal
government;

« develop proposals for federal agencies on behalf of small businesses;

« represent the views and interests of small businesses before federal
agencies;

« enlist the cooperation and assistance of public and private agencies,
businesses, and other organizations in disseminating information
about the federal government's programs and services that benefit

Since its establishment, a series of laws and executive orders has
increased Advocacy’s roles and responsibilities. First, in 1980 the White
House Conference on Small Business made recommendations that led
directly to the passage of the RFA, which requires government agencies
to consider the effects of their regulatory actions on smail entities and,
where possible, mitigate them.> Under the RFA, agencies provide a small
business impact analysis, known as an initial regulatory flexibility
analysis, with every proposed rule published for notice and comment and
a final regulatory flexibility analysis with every final rule.® The Chief
Counsel for Advocacy was charged with monitoring federal agencies’
compliance with the act and with submitting an annual report to
Congress.

4Prior to establishing a separate Office of Advocacy within SBA in 1976, Congress created
the position of Chief Counsel for Advocacy within SBA. See Pub. L. No. 93-386, § 10, 88
Stat. 749 (1974).

Sunder the RFA, the term “small entity” includes smail busi small g
and small organizations. 5 U.S.C. § 601(6). For the purposes of this report, we use the
term “small businesses” since that is our focus.

SWhen an agency can determine that the rule would not have a “significant economic
impact on a substantial number of small entities,” the head of the agency may certify to
that effect and forego the y flexibility ysis requi ts, (5 U.S.C. § 605).

Page 4 GAO-14-525 Office of Advocacy
735

Second, in 1996 the Smail Business Regulatory Enforcement Fairness
Act (SBREFA) provided for the judicial review of agency compliance with
key sections of the RFA. It also established a requirement that EPA and
OSHA convene panels whenever these agencies are developing a rule
for which an initial regulatory flexibility analysis would be required
(SBREFA panels).’ These panels consist of the agency, OIRA, and
Advocacy. The 2010 Dodd-Frank Act added the newly created CFPB to
the agencies required to convene SBREFA panels.® The SBREFA panels
meet with representatives of the affected small businesses to review the
agencies’ draft proposed rules, identify alternative approaches to the
rules, and provide insight on the anticipated impact of the rules on small
entities. The panels issue a report, including any recommendations for
minimizing the economic impact of the rule on small entities.

Third, Advocacy’s responsibilities were further expanded by Executive
Order 13272, which was issued in 2002. The order required each agency
to establish procedures and policies to promote compliance with the RFA
and to publish a response in the Federal Register to any written comment
received from Advocacy on rules published.® This requirement was
codified by the Smail Business Jobs Act of 2010.'° Executive Order
13272 also directs Advocacy to provide training to federal agencies on
how to comply with the RFA.

Until 2010, Advocacy’s budget was part of SBA’s. As of fiscal year 2010,
however, Advocacy was given statutory line-item funding in a Treasury
account separate from other SBA funding, with Congress setting the
amount available for Advocacy’s direct costs."* In fiscal year 2014,
Advocacy’s enacted budget was $8.75 million. Its fiscal year 2015 budget
request was $8.46 million. Of that amount, $7.75 million (92 percent) is to
be used to fund compensation and benefits for Advocacy’s professional
staff, with the balance of Advocacy's budget split almost equally between

7The Small Business Regulatory Enforcement Fairness Act of 1996 (P. L. No. 104-121,
title i).

®The Dodd-Frank Wall Street Reform and Consumer Protection Act (P. L. No. 111-203).
Executive Order 13272, Proper Consideration of Small Entities in Agency Rulemaking,
2002.

Pub. L. No. 1114-240, § 1601(4), 124 Stat. 2504, 2551 (codified at § U.S.C. § 604(a)(3)).
"See Pub. L. No. 111-240, sec. 1602(b)

Page 5 GAO-14-525 Office of Advocacy
736

external research and all other direct expenses."? Advocacy is organized
in five offices, as shown in figure 1.

Figure 1: Office of Advocacy Organizational Chart, Fiscal Year 2014

Chief Counsel Confidential

for Advocacy

Deputy Chief

Counsel for

Advocacy

[ L I ]

Office of Office of | Office of Office of Administrative
Interagency Economic Information Regional Support
Affairs Research Affairs Branch

Sourca: Offloe of Advocacy. | GAO-14-525.

Research Activities

Advocacy’s Office of Economic Research produces both internal and
external research, which is publicly disseminated, on a variety of small-
business issues. More specialized research—requiring proprietary data or
econometric analysis—typically is conducted by contractors (external).
SBA handles the contracting process for Advocacy. The contracts
generally last for 1 year. Advocacy economists act as the official
contracting officers’ representatives (contracting officer) overseeing and
coordinating the work of the contractors. The contracting officers maintain
a contract file for each external research product. Each year the Office of
Economic Research solicits research topics from Advocacy staff and
small business stakeholders, such as associations comprised of small
businesses. In addition, Congress requests studies, either formatly (by
putting the requirement into a law), or informally (through discussions with
Advocacy staff). A final list of potential research is presented to the Chief
Counsel before the beginning of the fiscal year, and the counsel chooses
the topics for the year. In fiscal year 2013, Advocacy produced 22

‘2Under Public Law 111-240, SBA must provide support to Advocacy, including office
space and equipment, communication and IT services, and equipment and facilities
maintenance. Therefore any costs of those services, as well as centralized indirect
expenses shared with other SBA offices, would appear in SBA’s budget request, not
Advocacy’s.

Page 6 GAO-14-525 Office of Advocacy
737

research products on topics that included access to capital, small
business exporters, entrepreneurship, and minority- and women-owned
businesses. Other Advocacy research addresses the concerns
highlighted in Advocacy’s authorizing statute, such as examining the role
of smail business in the American economy, assessing the effectiveness
of existing federal subsidies and assistance programs for small
businesses, and evaluating efforts to assist small veteran-owned smail

Advocacy follows a peer review process that was revised and formalized
in 2013 and applies to all internal and external research products.
Advocacy staff, including the Director of the Office of Economic
Research, conduct peer reviews for internal products. For external
research products, the peer review is initiated when Advocacy receives
the first draft of the product, typically 6 to 8 months after the contract has
been awarded, and generally includes external reviewers. In addition to
the peer review process, all of Advocacy’s research products are required
to pass Advocacy’s internal clearance process, which involves review by
the Director of Economic Research, editors in Advocacy's Office of
Information, and individuals in Advocacy’s Office of Chief Counsel (Senior
Advisor, Deputy Chief Counsel, and Chief Counsel).

Regulatory Activities

Advocacy's Office of interagency Affairs oversees the office’s regulatory
activities, which aim to convey the views of small businesses on the
impact of federal regulations and related costs. These activities generally
fall into three categories—developing and issuing comment letters,
convening information roundtables, and providing RFA training.“
Attorneys in this office (“regulatory attorneys”) are expected to become
experts in the policy areas they oversee and to establish and maintain
broad and effective networks of small business experts (e.g., trade
associations) in their policy area. The regulatory attorneys are
encouraged to go to trade association and other industry meetings in
order to maintain and expand those networks. in addition to maintaining
working relationships with industry members and experts, the staff are to

"Sp. L. No. 94-305, §202, 90 Stat. 668 (1976), as amended.
“The regulatory attomeys also engage with rulemaking agencies through the interagency

review process, which is run by OMB’s Office of information and Regulatory Affairs
(OIRA). However, OIRA and its operations are outside the scope of this report.

Page 7 GAO-14-525 Office of Advocacy
738

establish and maintain relationships with the regulatory staff within each
agency who write the rules.

One of the primary ways Advocacy provides input to agencies that are
issuing rules and regulations of concern to small businesses is through
public comment letters. Our review of comment letters from fiscal years
2009 through 2013 found that they covered a wide range of rulemakings
on issues such as food labeling, designations for critical habitat, and
emission standards. Advocacy made a number of recommendations in its
comment letters that included creating an exemption for small businesses
or strengthening economic analyses required by the RFA. Advocacy also
issued “nonrule” letters that involved the agencies’ other activities, such
as agencies’ scientific research. These letters constitute a small
proportion of Advocacy’s comment letters. Table 1 below shows the
number of comment letters on rulemakings by fiscal year.

Table 1: Advocacy Comment Letters by Policy Area, Fiscal Years 2009-2013

Fiscal year Fiscalyear Fiscalyear Fiscal year Fiscal year
2009 20

Policy area 10 2011 2012 2013 Total
Environment 4 9 40 6 7 43
Natural resources and agriculture 6 4 8 5 3 26
Safety and transportation 5 9 6 2 3 25
Banking and economic regulation 4 2 7 3 5 18
Food, drug, and health 3 4 6 0 3 16
Labor and immigration 1 3 6 4 1 12
P and small b 1 4 1 3 1 10
Rulemaking issues (no specific policy area) 2 1 3 3 0 9
Telecommunications and energy 3 2 2 2 0 9
Taxes, pensions, and securities 2 to) 4 4 4 8
Intellectual property 0 4 fe) oO 2 3
Not applicable 0 0 0 2 0 2
Total 35 39 53 28 26 181

Source: GAO analysis of Advocacy data, | GAO-14-525

Regulatory attorneys also convene information-gathering roundtables to
discuss the regulatory concerns of small businesses. Roundtables are
convened on a regular basis in two policy areas—environment and labor
safety—while events covering other areas are convened on an ad hoc
basis, depending on which regulatory or rulemaking issues might be
forthcoming. According to the regulatory attorneys, the most typical
reason for convening a roundtable was an upcoming rule or legislation

Page 8 GAOQ-14-525 Office of Advocacy
739

that wouid impact small businesses. The regulatory attorneys use the
information gathered from the roundtables, together with other
information, to inform Advocacy’s positions on the issues involved, and to
give Advocacy direction on proposed rules’ economic impacts and
possible regulatory alternatives. The attorneys also told us roundtable
discussions help them set priorities, and broaden their knowledge base.
The roundtables sometimes resulted in a comment letter, although not
always. Table 2 shows the number of roundtables by policy area for fiscal
years 2009 through 2013.

Table 2: Number of Roundtables by Policy Area, Fiscal Years 2009-2013

Fiscal year Fiscalyear Fiscaiyear Fiscal year Fiscal year
2009 2010 2011 201 20:

Policy area” 2 13 Total
Safety and transportation 14 9 9 9 8 4
Environment 7 10 44 9 7 44
Taxes, pensions, and securities 2 7 6 6 2 23
Banking and i i 0 1 0 4 1 6
Labor and immigration 1 1 3 1 0 6
Veteran issues 1 1 3 0 ie) 5
Intellectual property 0 1 1 1 0 3
Natural resources () 1 0 4 4 3
Labor safety/enviranment 0 0 9 2 0 2
Rulemaking issues (no specific policy area) 1 ce) 0 1 0 2
Procurement and smail business 0 1 0 9 0 4
Telecommunications 0 te) 1 0 () 1
Total 23 32 4 34 19 142

Source: GAO analysis of Advocacy data. | GAQ-14-525

“There are more policy areas for the roundtables since there are Instances where Advocacy hosted
roundtables in areas that did not have comment letters, such as veteran issues,

As discussed previously, Executive Order 13272 requires Advocacy to
provide training to the agencies on how to comply with the RFA.
According to data provided by Advocacy officials, in 2013, Advocacy staff
provided training on the RFA to 159 officials at nine agencies and to 22
congressional staff. In addition to the formal training sessions, regulatory
attorneys told us they were encouraged to interact regularly with the
relevant rulemaking officials at the agencies as rules were developed in
order to communicate the concerns of the small business advocates.

Page 9 GAO-14-525 Office of Advocacy
740

Advocacy’s Internal
Controls Do Not
Ensure the Quality of
Its Research and That
Required Information
Quality Practices Are
Followed

Producing research products, both internally and externally, on issues of
importance to small businesses is one of Advocacy's primary
responsibilities. However, we found that Advocacy’s quality review
process lacked some key controls to substantiate the quality of the
research and did not take steps to ensure that staff were adhering to
existing controls.

Advocacy’s Peer Review
Process Lacks Guidance
for Identifying Reviewers

According to Advocacy officials, peer review is the main quality control
over the research it disseminates. Advocacy’s current Chief Counsel
recently directed the office to strengthen its peer review process with the
intent to make it more rigorous and consistent. As a result, during the
course of our review, Advocacy finalized a written peer review process.
We found that the written guidance discussed the various levels of review
for internal and external products as well as a process for initiating peer
review. However, it did not specify how the economists who managed the
research products were to identify peer reviewers. Instead, Advocacy
Officials told us that they relied on their own expertise and professional
contacts to identify appropriate peer reviewers and provide
recommendations through the Director of Research and to the Chief
Counsel for Advocacy. The officials told us that within a specific subject
matter there is often a small group of available peer reviewers, in part
because their expertise is specialized and there are not many other
alternatives.

OMB's peer review guidance calls on agencies to select peer reviewers
with the appropriate knowledge and expertise and to take into account
their independence and lack of conflicts of interest."* Advocacy managers
told us that, in practice, the economists recommend peer reviewers based
on knowledge and experience in both subject matter and databases—as
discussed in the OMB guidelines. However, they did not provide specific
written guidance to the economists on how to identify peer reviewers.
Federal internal control standards state that internal control activities help
ensure that management's directives are carried out and in implementing

6 OMB, Final information Quality Bulletin for Peer Review, December 16, 2004,

Page 10 . GAO-14-525 Office of Advocacy
741

those standards management is responsible for developing the detailed
policies, procedures and practices for their agency's operations.'® With
additional guidance, Advocacy would be in a better position to help
ensure that the economists fully understand how best to identify qualified
peer reviewers and carry out the Chief Counsel’s directive to improve the
peer review process.

Advocacy Has Not
Consistently Documented
Peer Reviews

Advocacy does not have consistent documentation showing whether a
peer review occurred for all of its research products. Our review of 20
recent research products—10 internal and 10 external—revealed that 16
did not have documented peer reviews in the research files.” According
to interviews with Advocacy economists who managed the research, all of
the 20 products underwent some form of peer review. The economists
said that the type of review was commensurate with the methodological
complexity of each product, among other factors. However, the Advocacy
officials were unable to produce any documentation that peer reviews
occurred for these 16 products. According to Advocacy’s peer review
guidance, the economists who manage the research should document all
correspondence pertaining to the peer review and maintain this
documentation in the research file. In addition, federal internal control
standards require all transactions and significant events be documented
and that the documentation be readily available.

Advocacy officials do not have procedures to review the external research
files to ensure that the peer reviews were documented. Furthermore, they
noted that for some of the less in-depth internal research products—
typically 2 to 5 pages—such documentation would be administratively
burdensome.'® However, we note that the documentation could be
likewise concise, such as a checklist, or a form that reviewers sign,

‘8GAO, Standards for intemal Control in the Federal Government, GAO/AIMD-00-21.3.4
(Washington, D.C.: November 1999). These intemal control standards, first issued in
1983, present the intemal contro! for federal ies for both prog! and
financial management.

‘7Qf the 10 external products we reviewed, 6 did not contain documentation on whether a
peer review occurred. Of the 10 internal p we revi , None ined
documentation on whether a peer review occurred,

*8according to our analysis, of the 70 internal research products produced from fiscal
years 2008 through 2012, approximately 54 percent were shorter products, between 1 to 5
pages.

Page 14 GAO-14-525 Office of Advocacy
742

similar to the one currently used by Advocacy for its internal clearance
process. Otherwise, absent written documentation, Advocacy managers
are limited in their ability to conduct oversight and ensure that this key
quality control activity is happening. For example, for one of the internal
research products we selected for review, the study author no longer
worked at Advocacy, and therefore no one could tell us with any certainty
whether the required peer review had occurred, or who had participated
in it. Without adequate documentation—a key internal control-—of its peer
reviews, Advocacy does not have an institutional record of its activities
and cannot demonstrate that it is following its own peer review process.

In addition, Advocacy has not consistently documented how peer
reviewers’ comments were addressed by the authors of its external
research products. Of the 10 external research files we reviewed, 4 had
documentation that a peer review occurred, and 1 file included evidence
that the peer reviewer comments were incorporated into the final report.
Advocacy officials 'toid us that the economists who managed external
research consolidated the peer reviewers’ comments and forwarded to
the author those that needed to be addressed, including methodological
and data issues and other comments, but not those that might change the
scope of the contracted research."® They also told us that they did not
typically maintain documentation showing which comments had been
addressed and why, but included the final report in the research file.
However, Advocacy’s peer review process states that the economist
managing the research will analyze and incorporate, as needed, peer
reviewers’ suggestions and maintain all related documentation in the
tesearch file. However, since the economists are not keeping records and
documenting that comments have been considered and addressed,
management does not have an institutional record to provide reasonable
assurance that its quality control process is being followed.

*®According to Advocacy officials, it is not permissible to expand the scope of the research
or change the nature of the bles spi in the after an award has been
made, Therefore, if the peer revi s discuss that would result in
expanding the scope of the research (e.g., analyzing data from additional time periods),
those comments could not be accommodated.

Page 12 GAO-14-525 Office of Advocacy
743

Advocacy Has Not
Followed Some Required
Elements of Information
Quality Guidelines

While Advocacy has quality review policies for its peer review process, it
does not have policies and procedures that reflect the federal information
quality guidelines on retaining data for influential studies or taking other
steps to substantiate the quality of information in such studies when they
have not retained the data. Advocacy officials told us that they did not
retain the original data or underlying computer codes for three external
studies on the costs of regulation as required by the information quality
guidelines.?° We focused on external studies on estimating the costs of
regulation because it is a key research area for Advocacy, according to its
originating statute and the mission statement of its Office of Economic
Research. The OMB Information Quality Guidelines require that all
agencies producing and disseminating “influential statistical information”
help ensure a high degree of transparency about data and methods to
facilitate the reproducibility of such information by qualified third parties.
The SBA guidelines implement this standard for transparency by requiring
that the underlying data be stored and made available for public review
for as long as the agency-disseminated information based on the data are
valid. The guidelines also state that all formulas, calculations, matrixes,
and assumptions used in processing the data should be available.
Because Advocacy classified two of the regulatory cost studies as
“influential” according to the OMB guidelines, those data should have
been maintained.”"

Advocacy officials said that they did not maintain the data or models for
influential external research because there might be a cost associated
with obtaining such data, which would raise the costs of the studies,
possibly making them prohibitively expensive. However, in the case of
two of the studies, the original data were from publicly available sources
and involved a relatively small dataset, suggesting the cost would not

2°andy Bollman, E. H. Pechan & Associ ion of Barrier f Costs
Associated with the 2004 Americans with Disabilities Act (ADA) Accessibility Guidelines,
prepared for SBA Office of Advocacy, under contract SBAHQ-03C0020 (Washington,
D.C.: 2007); W. Mare Crain, The Impact of Regulatory Costs on Small Firms, prepared for
SBA Office of Advocacy, under contract SBHQ-03-M-0522 (Washington, D.C.: 2005); and
Nicole V. Crain and W, Mark Crain, The impact of Regulatory Costs on Small Firms,
prepared for SBA Office of Advocacy, under contract SBAHQ-08-M-0466 (Washington,
D.C.: 2010). We refer to the latter two studies as “the Crain studies.”

2The study by Andy Bollman and E. H. Pechan & Associates was also classified as
“influential.”

Page 13 GAO-14-525 Office of Advocacy
744

have been prohibitive.?? The OMB guidelines state that sufficient
transparency—achieved in part by storing the relevant data—resuits in
analyses that can be substantially reproduced. Not retaining the
underlying information for these influential research papers makes it
much more difficult to assess the quality of that work, including its
objectivity—a key goal of the information quality guidelines.

We also found that Advocacy staff had not taken additional steps, in the
absence of retaining the underlying data, to substantiate the quality of the
tegulatory cost estimates in two of the studies that it sponsored and
disseminated.”* The OMB guidelines state that when data and methods
are not retained and made available to the public because of other
compelling interests such as privacy, trade secrets, intellectual property,
and other confidentiality protections, the agency shail apply rigorous
checks to the analytical results and document what checks were
undertaken. Because Advocacy had not retained data on the two cost
estimation studies that had been criticized, we interviewed senior
Advocacy officials, including the Director of its Office of Economic
Research, about the information and methodologies used in the studies.
We asked them a set of questions related to criticisms of the
methodologies, data, and models used in the studies that were identified
in our evaluation and the work of other researchers, Advocacy staff
declined to answer many of our questions and instead directed us to the
authors, stating that they, not Advocacy economists, were the experts on

221m the case of the 2010 Crain study, the original underlying data for the
regulation cost regression were publicly available from the World Bank and the

1p story « and the study's regressions
contained only 118 records and 6 exp! , Since the
regression models employed in the studies consisted of one equation each, we do not
believe there would have been sig: it costs. with ig the Crains to

provide Advocacy the data and computer coding written to produce the estimates. While
Advocacy did not classify the 2005 Crain study as “influential” according to the OMB and
SBA criteria, because the 2005 study used similar methodologies, we examined them
together.

23We asked Advocacy officials how they substantiated the two Crain studies. We did not
ask the Advocacy officials to verify the quality of the third regulatory cost study (Evaluation
of Barrier Removal Costs Associated with the 2004 Americans with Disabilities Act (ADA)
A ibility Guideli b our work did not reveal the same level of
methodological weaknesses that we identified in the Crain studies.

Page 14 GAO-14-525 Office of Advocacy
745

the issues covered in the studies.2* However, the authors would not
speak with us, stating that they were no longer contractually obligated to
respond to our requests for information.

During our discussions with Advocacy officials, they stated that the
purpose of the studies was not to estimate the overall costs of
regulations, but rather to estimate the disproportionate share borne by
small businesses. They also noted that, as with all contract research, the
external research reports contain a disclaimer indicating that the views
presented did not necessarily represent those of Advocacy. In addition,
Advocacy added language to the 2010 report's cover page about the
uncertainty of the authors’ estimates of the costs of regulation.?5
Advocacy officials noted that the majority of the research it conducts is
not classified “influential” according to the OMB and SBA guidelines, and
that they have no plans to engage in such work in the near future.
However, given Advocacy’s mission, it may do influential research in the
future as it has in the past even if on a limited basis. We acknowledge
that these reports may not necessarily be representative of all Advocacy’s
research efforts, but not substantiating the quality of the information in
even one study could call into question the credibility of Advocacy's
research program. Thus, establishing policies and procedures that reflect
the federal information quality guidelines on retaining data for influential
studies or when such data are not retained because of certain compelling
interests, and requiring additional steps to substantiate the quality of the
information, would put Advocacy in a better position to provide
reasonable assurance about the quality of its research program.

OMB Information Quality Guidelines require that agencies develop
policies to ensure that managers be able to substantiate the quality of
information they disseminate. The guidelines also discuss narrow

24 advocacy officials also provided us with the Crains pi in to
earlier criticisms by others of the studies. However, the rebuttals do not directly address
important criticisms.

25This one-page statement notes, among other things, that “The study is a top-down
analysis of regulatory costs that uses certain assumptions to estimate totals, and is not a

bottom-up precise accounting of the overall cost of 0, te says:
“The overall figure of $1.75 trillion in costs is derived from a number of different
assumptions and sources to create an estimate. As with almost any academic

gy, it was not i to be idered a precise finding.” "For the full
statement, see the report, available on Ad’ y's website, don April 24, 2014,

Page 15 GAO-14-525 Office of Advocacy
746

circumstances under which an agency does not have to substantiate the
quality of the information that resulted from a research project of one of its
contractors or grantees. In those circumstances, the researcher is to
make clear with an appropriate disclaimer that the views expressed in the
research are his or her own and do not necessarily reflect those of the
agency. However, OMB cautions that “if an agency, as an institution,
disseminates information prepared by an outside party in a manner that
reasonably suggests that the agency agrees with the information, this
appearance of having the information represent agency views makes
agency dissemination of the information subject to these guidelines.”

As we noted previously, Advocacy placed a disclaimer on the two studies,
but its actions indicate its agreement with the information in the studies.
First, Advocacy made the two studies available on its website, where they
continue to be available. Second, Advocacy’s disclaimer that appeared on
the 2010 study noted that it contained information and analysis that was
reviewed and edited by Advocacy. Advocacy’s description of its review
role suggests that the agency contributed to the content, if not the
conclusions of the study. Finally, several Advocacy comment letters have
cited the 2005 study's regulatory cost estimates in support of their
arguments.”” Because Advocacy’s actions raise, at the least, an
appearance of agreement with the information contained in the studies,
we believe that the office was required to substantiate the quality of the
estimates of the economic costs contained in the studies.

28OMB. Guidelines for ing and Maximizing the Quality, Objectivity, Utility, and

grity of ion Dis ir by Federai Agencies. 67 Fed. Reg. 8452 (Feb 22,
2002).
27See Ad y letter to Envi Pi ion Agency, dated November 28, 2008,

Re: Comments « on EPA’s Advance Notice of Prop
Greenhouse Gas Emissions under the Clean Air Act,” Docket 1D No. EPA-HQ- OAR-2008-
0318; Advocacy letter to Environmental Protection Agency, dated June 23, 2009, Re:
Docket ID No. EPA-HQ-OAR-2009-0171, Ce on EPA's ‘F

and Cause or Contribute Findings for Greenhouse Gases Under Section 202(a) of the
Clean Air Act’, Advocacy letter to National Marine Fisheries Services, Department of
Commerce, dated October 30, 2009, Re: RIN 0648-AW18 Magnuson-Stevens Fishery
Conservation and g Act: Regi Fi ig Councils;
Operations.

Page 16 GAO-14-525 Office of Advocacy
747

Documentation of
Key Regulatory
Activities is
Inconsistent and
Roundtables Are Not
Publicized According
to Advocacy’s Policies

Advocacy has practices and procedures (“policies”) for its regulatory
activities—comment letters and roundtables—however, documentation of
these key regulatory activities is inconsistent. Furthermore, while we
determined that transparency and other requirements in FACA do not
apply to Advocacy's roundtables, Advocacy is not following its internal
policies meant to ensure its roundtables are as open to the public as they
could be. As a result Advocacy cannot demonstrate that it is always fully
meeting its mission to foster two-way communication between small
businesses and federal policymakers.

Advocacy’s
Documentation for Key
Regulatory Activities Is
Inconsistent

Our review of Advocacy’s key regulatory activities—developing and
issuing comment letters and convening information roundtables—found
that Advocacy staff are inconsistently maintaining documentation of key
decisions and events. In April 2014, Advocacy provided us with a
“practices and procedures guide” for the Office of Interagency Affairs,
dated March 2014. The guide covers staff activities related to initiating
comment letters and convening roundtables, among other things.
Advocacy management told us that they update the guidance periodically,
including amending it during the course of our review to make it clear that
the decision to issue a public letter or hold a roundtable rests with the
Chief Counsel for Advocacy. However, our review found that the updated
guide continued to lack policies for documenting key decisions and
activities. For example, the guide stated that when regulatory attorneys
decide to intervene in the rulemaking process, they must follow up, as
appropriate, with the interested associations to ensure that Advocacy has
sufficient information and data to make its case for intervening. But there
is no policy to document these interactions. The following are other
instances where we found a lack of policies to document key activities.

« Small Business Input into Comment Letters. Advocacy does not have
any policies requiring that the regulatory attorneys retain
documentation showing which entities provided input into comment
letters, and we found that the attorneys do not consistently do so. Our
analysis of Advocacy’s comment letters found that about 57 percent of
the letters referenced small business input or concerns. But when we
interviewed seven regulatory attorneys about how they developed
comment letters generally, some told us that they maintained a record
of the entities providing input for specific letters, but others said that
they did not. Further, when we asked Advocacy staff for
documentation on the sources of the smail business input referred to

Page 17 GAO-14-525 Office of Advocacy
748

in a nonrepresentative sample of 11 comment letters, they were
unable to provide specific emails or notes of conversations.”*

« Reasons for Convening Roundtables. Advocacy's practices and
procedures guide states that the Chief Counsel must approve the
proposed agenda, speakers, and discussion topics for ail proposed
roundtables before participants are invited. But the guide contains no
policy that this step be documented. We interviewed seven regulatory
attorneys responsible for the roundtables and their management and
were told that the attorneys set agendas and selected speakers based
on their own assessment of the issues and, in some cases, with
suggestions from smail businesses or interested industry parties.
Advocacy officials emphasized that they only held roundtables when
there is sufficient interest or need on the part of small businesses.

+ Roundtable Discussions and Participants. information gathered from
the roundtables is used to inform Advocacy's positions on issues
related to small businesses and in comment letters, but Advocacy’s
guidance contains no policies to document roundtable discussions.
Our content analysis of Advocacy’s comment letters showed 19
percent of them referred to roundtable discussions. However, staff did
not routinely take and maintain notes of the discussions, according to
the interviews we conducted with the regulatory attorneys. In addition,
not all staff take attendance at the events. In most cases, Advocacy
staff keep an “RSVP list” of those who have indicated that they will
attend. However, some of the staff noted that the RSVP lists may not
include all participants, including those on the phone. As a result it is
difficult to determine the extent to which small businesses and related
entities were represented at these events.

Advocacy officials told us that they did not have guidance on maintaining
documentation on the sources of input to comment letters or on
roundtable discussions because they did not feel that setting such
standards was required to fulfill their duties under Advocacy’s statute.
Furthermore, they noted that, in the case of roundtables, keeping records
in a manner that identified specific speakers would inhibit discussion and
limit their ability to gain valuable input. They also cited logistical
challenges in taking accurate attendance at larger events. We
acknowledge that specific parties might not want to be publicly named,
but federal standards for internal control call for agencies to document

28We selected a nonrepresentative sample of recently published comment letters—
published from 2011 through 2013—weighting our choices of letters to reflect the
distribution of policy areas listed in table 2.

Page 18 GAO-14-525 Office of Advocacy
749

significant events. Taking steps to balance the need for privacy so
individuals can speak freely, with a commitment to maintain a basic level
of documentation of these events—that is, documenting which entities
provided input into its comment letters and roundtables—could help
Advocacy demonstrate that it is meeting its mission to represent the
interests of small businesses.

Advocacy’s Policy for
Publicizing Information on
Roundtable Events Is Not
Followed

Key documents for Advocacy’s roundtables—agendas and presentation
materials—are not made available to the public at-large after the fact. The
regulatory attorneys cultivate email lists of relevant stakeholders who are
invited to roundtable events, and these lists are continually updated. It is
Advocacy’s policy to add any interested parties to the invitation list, if
asked, and several of the attorneys we interviewed said they did so. They
also told us they made agendas and presentations available to any
interested parties who requested them after the roundtable. However, the
agendas and presentations are not posted to the website or made
publically available in any systematic way and if small businesses and
other interested parties do not know about the roundtables, they cannot
request information from the events.

Advocacy’s policies and procedures state that agendas and presentations
should be posted on Advocacy’s website. Advocacy officials stated they
had been unable to post roundtable materials to the website, which SBA
maintains, because of difficulties in meeting certain readability and
accessibility requirements in the Americans with Disabilities Act.?°
However, a variety of other Advocacy reports and publications are posted
on its website that also must meet these requirements, and Advocacy
officials did not explain why information on the roundtables could not be
likewise included. Making the roundtable materials available on its
website would strengthen Advocacy’s efforts to inform small businesses
and other interested parties about its efforts to represent their interests to
federal decision makers.

2942 U.S.C. § 12101 et seq.

Page 19 GAO-14-525 Office of Advocacy
750

Federal Advisory
Committee Act
Requirements Do Not
Apply to Advocacy’s
Roundtables

In addition to evaluating whether Advocacy publicizes and conducts its
roundtables in accordance with its internal policies and procedures, we
also analyzed whether Advocacy’s roundtable groups constitute “advisory
committees” subject to the public notice and other transparency
requirements of FACA.*° We found that the roundtables are not advisory
committees, and thus Advocacy is not required by law to follow these
rules. We first determined that Advocacy is an “agency” covered by
FACA. It is an “authority of the Government of the United States, whether
or not it is within or subject to review by another agency.”*' In addition,
Advocacy possesses the type of “substantial independent authority”
required by the courts. While located within SBA, Advocacy is
independent of SBA, and it has distinct statutory authorities and
responsibilities, a separate statutory charter, and an appropriation
account that is separate from the rest of SBA. Furthermore, its duties and
authorities under statute and Executive Order are substantial and its
recommendations made in furtherance of small entities’ concerns must,
by law, be given considerable weight by other agencies.

While we found that Advocacy is a FACA “agency,” we concluded that its
roundtable groups are not “advisory committees" as defined by the statute
and interpreted by the courts and implementing regulations. A covered
advisory committee is a panel, task force, or similar group created or
used by an agency for the purpose of providing advice or
recommendations on particular matters. Participants’ input must be
sought as a group, not as a collection of individuals. The formality and
fixed structure of the group also is an important factor in determining
coverage under FACA. Advocacy does not seek roundtable participants’
input as a group, however; rather, attendees provide their individual
perspectives on the agency rule or policy under discussion, do not
significantly interact with one another, and no attempt is made to reach a
consensus, Advocacy’'s roundtables also do not have the requisite
organized or fixed structure; rather, as noted, Advocacy's policy is to
extend roundtable invitations to anyone who expresses a desire to attend.
Finally, according to Advocacy, it is the agency itself, not the roundtable
participants, that develops policy advice and recommendations, albeit
based in part on the data and information provided by roundtable
participants (as well as obtained elsewhere). Our detailed legal analysis

305 U.S.C. App. Il.
315 U.S.C. App. Il, § 3(3), incorporating 5 U.S.C. § 551(1) (Administrative Procedure Act).

Page 20 GAOQ-14-525 Office of Advocacy
751

of the applicability of FACA to Advocacy’s roundtables is contained in
appendix fll.

Advocacy’s
Workforce Planning
Efforts Lack
Succession Planning

Workforce planning presents some challenges for Advocacy, in part
because the office is small and has a large number of positions, which,
according to Advocacy officials, typically are replaced with each new
administration. While the office currently does some workforce planning,
its efforts do not include the long-term strategic plans that would help
ensure that it maintains the expertise and skills needed to fulfill its
mission. While Advocacy now has responsibility for developing its own
budget, goals, and performance measures, our review of its strategic plan
and goals did not find goals or objectives that discussed workforce issues
such as staff development and succession planning. Advocacy officials
told us that they used their organizational chart as the basis for their
workforce planning efforts and discussed workforce issues with staff and
managers at meetings as needed (see fig. 2). Advocacy officials said that
because Advocacy was a small office with only 46 staff, the
organizational chart and meetings to discuss staffing issues met their
workforce planning needs. Advocacy officials told us that to develop staff
they provided training to regulatory attorney and economist staff, had
established a mentoring program for newer staff, and were implementing
a knowledge-sharing database to help staff develop expertise in
specialized policy areas.

Figure 2: Office of Advocacy Organizational Chart, Fiscal Year 2014

Chief Counsel Confidential
for Advocacy 1 2

Office of Office of Office of Office of Administrative
interagency Economic Information Regional Support
Affairs 12 Research 7 6 Affaire "t Branch 6

Source: Office of Advocacy. | GAO-14-525
When we asked Advocacy officials about succession planning and their

plans for addressing the departure of senior or experienced staff, the
Officials told us that most of the turnover in staff occurred during changes

Page 21 GAO-14-525 Office of Advocacy
752

in administration. For example, according to Advocacy officials, the
change of administration in 2009 resulted in the turnover of at least 15 of
20 senior officials. Among these were the 10 regional advocates, who are
located in each of SBA’s regional offices across the country, and make up
the Office of Regional Affairs. Turnover tends to be low among the
economists and regulatory attorneys, some of whom have been with the
office for years. Advocacy officials said that because rulemaking often
took so long, they generally had enough time to hire or realign any staff
as needed.

According to federal internal control standards, effective management of
a workforce is essential to achieving program results. Our body of work
on workforce planning has demonstrated the importance of such planning
and the need to develop long-term strategies—such as training and
succession planning—for acquiring, developing, and retaining staff to
achieve programmatic goals.°* OPM’s Human Capital Assessment and
Accountability Framework states that agencies and offices with workforce
planning are better able to manage their staff by, for example, ensuring
that systematic processes are in place for identifying and addressing any
gaps between current and future workforce needs. Further, OPM
recommends that succession planning is needed to ensure continuity in
leadership positions. In addition, workforce planning can help
management determine the type of training and other strategies that are
needed to address factors such as projected retirements and succession
planning. In past work on succession planning, we have found that in
addition to focusing on replacing individuals, succession planning
strategies can also strengthen current and future organizational
capacity.°*

Given the length of time some attorneys and economists have been with
Advocacy, the loss of their expertise through retirement, among other
things, could leave significant gaps in needed skills and knowledge,
according to Advocacy officials. Yet Advocacy has not incorporated

%2GA0, Human Capital: Key Principles for Effective Workforce Planning, GAO-04-39 ;

{Washington, D.C.: Dec. 11, 2003), and and ip ig
Personnel Managements is Critical for Agency's Efe i SOS att (Washington,
D.C.: July 18, 2013).

33GA0, Human Capital: ities to Ei Existi

Succession Planning and MenogonontE Eons, yar 05-585 Washington D.C.: June 30,
2005).

Page 22 GAO-14-525 Office of Advocacy
753

succession planning into its workforce planning efforts, such as its
training and mentoring initiatives. Further, Advocacy officials told us that
they discussed future staffing needs and various options for addressing
them, including training, but these efforts are not documented in a
manner that would ensure consistent implementation. However, ensuring
that activities such as staff training are consistently implemented is
particularly important when senior management can change significantly
every 4 or 8 years. Without incorporating long-term succession planning
into its workforce planning efforts, Advocacy is not in the best position to
ensure that it has qualified staff to fill leadership and other key positions
and a skilled workforce able to meet the demands of its mission on behalf
of small businesses.

Conclusions

Effective internal controls are critical for the Office of Advocacy if it is to
achieve program outcomes and minimize operational problems.
Recognizing this, Advocacy recently has taken action to improve some of
its guidance and controls. However, Advocacy’s research, regulatory, and
workforce planning functions could be improved by strengthening its
internal controls as follows:

« Research activities. \n its research operations, Advocacy has taken
some initial steps toward establishing stronger control policies by, for
example, formalizing its peer review process for internal and external
research products. However, the guidance provided did not include
information on how to select appropriate peer reviewers—the experts
whom Advocacy relies on to assess the quality of the research that it
disseminates. The guidance also lacks policies for documenting that a
peer review occurred and how reviewer comments were addressed
for its external research products. Such guidance would help ensure
that Advocacy research staff fully understand how best to identify the
most qualified peer reviewers, and how to document and incorporate
reviewer comments. In addition, Advocacy did not follow federal
guidelines for information quality for influential studies that set out
requirements for retaining data and taking additional steps to
substantiate the quality of information it disseminates when it has
certain compelling reasons to not retain the data. Improving policies
and procedures for its research activities would help support
Advocacy’s mission to provide quality research on small business
issues that decision makers and the public can rely on.

« Regulatory activities. Advocacy's lack of documentation and
transparency of the regulatory activities we reviewed made it difficult
to validate Advocacy’s efforts to represent small businesses.

Page 23 GAO-14-528 Office of Advocacy
754

Specifically, weaknesses exist in Advocacy’s documentation of both
the sources of the small business input in comment letters and the
views of small businesses discussed and conveyed at its roundtables.
As a result, the extent to which the small businesses’ views on
regulations were being obtained and communicated is unknown.
improving its guidance to staff on its regulatory activities and
emphasizing the importance of documentation would enable
Advocacy to more effectively demonstrate to decision makers that it
was obtaining and communicating the interests of small businesses.
In addition, Advocacy is not following its internal policy to post
materials from roundtables on its website. As a result, itis missing an
opportunity to reach out more broadly to small businesses and other
interested parties and increase the transparency of its activities.

« Workforce planning activities. While Advocacy's workforce planning
efforts help in managing its current staff, these efforts do not include
any strategies to plan for succession, even though several staff have
been with the office for many years and will eventually need to be
replaced. Without this important element of workforce planning,
Advocacy could be in a vulnerable position when critical staff leave
the agency or staff face new demands. Although Advocacy is a
relatively small office, having a skilled workforce is critical to meeting
its mission. Succession planning would help ensure that Advocacy
was better prepared to maintain qualified staff to conduct its research
and regulatory activities in support of small businesses.

Recommendations for
Executive Action

To improve Advocacy’s system of internal control, and help to provide
reasonable assurance that the office is meeting its mission, we
recommend that the Chief Counsel of Advocacy take the following five
actions:

« Strengthen the accountability of its research activities by taking the
following two actions:

« Enhance its peer review policies and procedures by including
written guidance on selecting peer reviewers and documenting all
steps of the peer review process—whether a peer review occurred
and how and to what extent peer reviewer comments were
addressed.

e Develop policies and procedures that reflect the federal
information quality guidelines on retaining data for influential
studies, and when not retaining data, taking additional steps to
substantiate the quality of information disseminated.

« Strengthen the accountability of its regulatory activities by developing
policies and procedures to ensure that key elements of that work—

Page 24 GAO-14-525 Office of Advocacy
755

such as sources of input for comment letters and roundtable
discussions—are consistently documented.

« Coordinate with SBA officials who oversee website administration to
comply with Advocacy’s roundtable policy to make information on the
events—agendas, presentation materials—publicly available on its
website so that its regulatory activities are more transparent to the
public.

e Improve its workforce planning efforts to be better prepared to meet
its future workforce needs by incorporating succession planning.

Agency Comments

We provided a draft of this report to Office of Advocacy for its review and
comment. In its written comments (reproduced in app. II), Advocacy
agreed with our recommendations. Advocacy stated that for its research
activities, its current effort to further formalize procedures for the peer
review process will include steps for additional documentation and that it
also plans to develop written guidelines for determining which research
products are considered influential, which will clarify when Advocacy
needs to take additional information quality steps. Advocacy also said that
as it develops how it will disseminate information about its regulatory
activities, it will incorporate approaches that are responsive to our
recommendations. Finally, Advocacy agreed that workforce planning is
important for ensuring that the office maintains the skills and resources
needed to fulfill its mission and noted that the office is developing a
Leadership Succession Plan in response to our recommendation.

Page 25 GAQ-14-525 Office of Advocacy
756

We are sending this report to the Office of Advocacy and interested
congressional committees. The report also will be available at no charge
on the GAO website at http:/Avww.gao.gov. If you or your staff have any
questions about this report, please contact Cindy Brown Barnes at (202)
512-8678 or brownbarnesc@gao.gov. Contact points for our Offices of
Congressional Relations and Public Affairs may be found on the last page
of this report. GAO staff who made major contributions to this report are
listed in appendix V.

Sincerely yours,

Cindy Brown Barnes
Acting Director, Financial Markets and
Community Investment

Page 26 GAQ.-14-525 Office of Advocacy
757

Appendix |: Objectives, Scope, and
Methodology

This report examines Advocacy's (1) research activities; (2) regulatory
activities, including the applicability of the Federal Advisory Committee
Act (FACA) to Advocacy’s roundtables; and (3) workforce planning
efforts. The scope of our work covered key activities conducted from
fiscal year 2008 to fiscal year 2013, although in some cases, we
broadened that scope to include fiscal years 2005 through 2008, as noted
below.

To understand Advocacy’s mission, operations, and participation in the
rulemaking process, we reviewed relevant laws and regulations,
Advocacy documents, including its annual reports to Congress on the
Regulatory Flexibility Act (RFA), budget and strategic planning
documents, and other publications.

To assess Advocacy's research activities, we determined: how Advocacy
staff chose its research topics; how they conducted the research; and
what controls they had in place to ensure quality products. We analyzed
Advocacy’s research products produced in the 5 most recent fiscal
years—2008 through 2012—and interviewed relevant Advocacy officials
on the processes by which they assess the quality of its research
products.' To evaluate Advocacy’s research activities, we analyzed a
nonprobability sample of research, which included 10 research products
authored by Advocacy staff (internal), and 10 products produced by its
contractors (external). To select a sample of internal research products
that best represented the variety of internal research, we reviewed the 58
research products issued from fiscal years 2008 through 2012, and
categorized each as either “routine” (meaning published either quarterly
or semi-annually, and relying on the same underlying data set), or as
“nonroutine.” Within the routine category, we selected the mostly recently
published product from each of the following routine publications: (1)
Small Business Profiles of the States and Territories, (2) Small Business
Quarterly Bulletin, (3) Quarterly Lending Bulletin, (4) Small Business
Lending, and (5) The Small Business Economy. For the nonroutine
products, we created five categories, such as “analysis” and “fact sheets.”
We selected, from each of those five categories, the most recently
published report. Then, for each of the 10 selected internal research
products, we used a data collection instrument and interviewed the

1For the period we conducted our audit, not all the internal research eych publish for fiscal
year 2013 were availabie in ail cases, so we f on intemal d from
fiscal years 2008 through fiscal year 2012.

Page 27 GAO-14-525 Office of Advocacy
758

Appendix |: Objectives, Scope, and
Methodology

Advocacy staff who wrote the products in order to see to what extent the
products adhered to Information Quality Guidelines issued by the Office
of Management and Budget (OMB) and the Smail Business
Administration (SBA) and Advocacy’s internal quality review process
(“peer review’).? To assess the quality of the peer review used for
Advocacy’s external research, we reviewed the contract files for the 10
most recently published external research products, as of year-end 2013,
and compared how the work was produced, including Advocacy's peer
teview process, against the OMB Peer Review Guidance and OMB and
SBA information quality guidelines, and applicable federal internal control
standards.° The results from our reviews cannot be projected to all
Advocacy studies, but they provide an indication of how Advocacy staff
conducted or oversaw the research and what controls were in place to
ensure quality products.

We also assessed Advocacy's contract studies that focused on the
economic costs of regulation. We focused on external studies in these
areas because they are key research areas for Advocacy, according to its
originating statute and the mission statement of its Office of Economic
Research. For the economic costs studies, we assessed them against
OMB and SBA Information Quality Guidelines, and examined Advocacy's
compliance with related data retention policies therein. We also reviewed
peer reviewers’ comments and other external reviews on the studies as
part of our assessment. Lastly, we interviewed Advocacy officials to
obtain information on steps they took to substantiate the quality of
information for influential studies when data are not retained.

20MB, Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and
Integrity of information Disseminated by Federal Agencies (Washington, D.C.: February
2002). 67 Fed. Reg. 8452 (Feb. 22, 2002). Agencies were required to issue their own
implementing guidelines by October 1, 2002. For SBA's guidelines, accessed on April 24,
2014, see http:/Awww.sba.gov/about-

ba/sba_per /open_gover infe ion_quality/inf ion_quality.
s.

30MB, Final Information Quality Bulletin for Peer Review, December 16, 2004. This
Builletin established government-wide guidance aimed at enhancing the practice of peer
review of g science

4ad y's studies ining total costs of regulation to the U.S. economy have been
conducted approximately every 5 years, according to Advocacy officials. For this reason,
we broadened the scope to fiscal year 2005, whereas in other research work, we focused
on fiscal years 2008 through 2012.

Page 28 GAO-14-525 Office of Advocacy
759

Appendix I: Objectives, Scope, and
Methodology

To evaluate Advocacy's regulatory activities, we assessed: how and why
Advocacy decides to issue comment letters and convene roundtables; the
policies and practices in place that pertain to those activities; how
Advocacy staff solicit input from smail businesses and other parties. We
interviewed relevant staff, as described below; reviewed relevant policies
and procedures, and analyzed comment letters produced and
roundtables convened from fiscal years 2009 through 2013.° Specifically,
we performed a content analysis on the 181 comment letters issued
during that period, using NVivo software, to analyzed and categorize the
content of the letters and the nature and source of the small business
input provided.® We also interviewed Advocacy staff who are responsible
for rulemaking and related activities, weighting our choices of
interviewees to reflect the distribution of comment letters by policy area,
and reviewed supporting documentation for comment letters to
understand how Advocacy staff develop and issue comment letters, and
compared this information to federal internal control standards.

Similarly, we reviewed available information on the 142 roundtables
convened during the same 5-year period and interviewed the responsible
Advocacy staff, weighting our choices of interviewees to reflect the
distribution of roundtables by policy area. We reviewed Advocacy’s
policies for roundtables to understand their origin, purpose, and
documentation requirements, and compared this information to federal
internal control standards. In order to understand the perspective of those
who attended the roundtables, we attended three of the events. In
addition, we selected and interviewed a nonprobability sample of past
participants from email lists provided by Advocacy's regulatory attorneys.
Specifically, we talked to the following representatives: five from industry
associations that represent small and large businesses; one from a large
corporation; and one nonprofit organization whose mission relates to
policies or rules under consideration.’ We made our selections to include

5$imilar to our app in ing Ad "s research work, we wanted to focus on

the five most recent fiscal years. In the case of the regi y letters
and roundtables—information was available through the end of fiscal year 2013.

NVivo is a qualitative data analysis soft system that allows organization and analysis
of information from a variety of sources including complex nonnumeric or unstructured
data.

Separate from interviewing the officials selected from the roundtable invitation lists, we
interviewed rep ives from an iation that rep small busi anda
nonprofit whose mission relates to transparency in government. We discussed
roundtables and other Advocacy activities with these parties.

Page 29 GAOQ-14-525 Office of Advocacy
760

Appendix |: Objectives, Scope, and
Methodology

representatives from a variety of sources, and while the results from our
interviews cannot be projected to ail entities that interact with Advocacy,
the information we gathered does provide insights into how the selected
groups view Advocacy and its work in representing small businesses to

federal policymakers.

We also reviewed Advocacy’s training to agency staff in how to comply
with the RFA and interactions with agency rulemaking officials. In
addition, we interviewed officials from the entities that interact with
Advocacy in rulemaking—the Environmental Protection Agency (EPA),
Occupational Safety and Health Administration (OSHA), Bureau of
Consumer Financial Protection, also known as the Consumer Financial
Protection Bureau (CFPB), and Office of Management and Budget's
(OMB) Office of Information and Regulatory Affairs (OIRA).

To analyze whether FACA (5 U.S.C. App. II) applies to Advocacy’s
roundtables, we reviewed relevant statutes, case law, regulations, and
guidance. In addition, we reviewed and considered Advocacy’s written
views on the issue. See appendix III for more information on the legal
analysis we conducted.

Finally, we reviewed Advocacy’s workforce efforts. To understand
Advocacy's workforce planning, we reviewed Advocacy’s strategic goals
and other planning and budget documents and interviewed senior
management to determine what, if any, policies and procedures were in
place related to workforce and succession planning. We assessed any
such policies and procedures against applicable federal standards for
internal control and the Office of Personnel Management’s (OPM) Human
Capital Assessment and Accountability Framework (HCAAF).® We also
reviewed GAO reports on workforce and succession planning to gain
insights about key practices and how agencies have used them.

We conducted this performance audit from August 2013 to July 2014 in
accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objectives. We believe that

Suman R in ies, HCAAF and HCAAF Systems, Standards,
and Metrics, 73 Fed. Reg. 23012 (Apr. 28, 2008).

Page 30 GAO-14-625 Office of Advocacy
761

Appendix i: Objectives, Scope, and
Methodology

the evidence obtained provides a reasonable basis for our findings and
conclusions based on our audit objectives.

Page 34 GAO-14-525 Office of Advocacy
762

Appendix Il: Comments from the Office of
Advocacy, Small Business Administration

SBA Office of Advocacy
409 3rd Street, SW
Washington, DC 20418
ofA y
[wwwsbeseviedversey] Aclyocacy: the voice of small business in government

July 11,2014

Ms. Cindy Brown Barnes

Acting Director, Financial Markets and Community Investment
U.S, Government Accountability Office

441 G Street, NW

Washington, DC 20548

Dear Ms. Bames:

Thank you for providing the SBA Office of Advocacy with a copy of the Government
Accountability Office (GAO) draft report entitled Office of Advocacy Needs to Improve Controls
Over Research, Regulatory, and Workforce Planning Activities. We have reviewed GAO's
recommendations and welcome the opportunity.to comment, In addition, Advocacy appreciates
the time and effort GAO took to understand how we fulfill the unique mission of our office.

The following reference dations put forth by GAO:

© Research Activities

Ad GAO's our research activities, As.
GAO states, Advocacy is currently working on guidance to further formalize procedures
for the peer review process, which will include ad di ion. Advocacy also
plans to develop written guidelines for ining what Ad research products
would be considered “influential,” which will further clarify needed information quality
checks. Advocacy agrees with GAO that such steps will strengthen our ability to provide
robust and quality economic research for small businesses and policymakers.

© Regulatory Activities

Advocacy's use of comment letters and roundtables is central to our mission to advocate.
for small busi and we appreciate GAO's ion to improve our
documentation of these activities. Advocacy will continue to develop how we
disseminate information about our regulatory activities in ways that are both responsive

to the GAO ions and in of Ad y's mission,
© Advocacy's Workforce Planning Activities
GAO that Ad y improve our work planning efforts by
i i planning. Ad: Y agrees that work planning is an

Page 32 GAO-14-525 Office of Advocacy
763

Appendix il: Comments from the Office of

¥

important part of ensuring that our office maintains the skills and resources needed to
fulfill our important mission. As a result of this GAO recommendation, Advocacy is
developing a Leadership Suecesion Plan that will formalize existing and foture
workforce planning efforts.

Also, GAO agreed with SBA and Advocacy that Federal Advisory Committee Act requirements

do not apply to Advocacy’s roundtables. Advocacy values the thorough investigation that GAO

businesses and these findings will help our office to continue this important part of our outreach,

The SBA Office of Adv is itted to conti to fulfill our mi: as the

independent voice for small business by researching small business issues and providing input
into federal rulemaking and related regulatory activities,

Sincerely,

Cleudia Rayford Rodgers
Deputy Chief!

Page 33 GAOQ-14-525 Office of Advocacy
764

Appendix III: Legal Analysis of the Applicability
of the Federal Advisory Committee Act to the
Office of Advocacy’s Roundtables

Introduction and Summary As part of our review of the Small Business Administration Office of

of Conclusions Advocacy’s (Advocacy) activities in identifying and communicating the
concerns of small businesses and other smail entities as agencies
develop regulations and policies, we analyzed whether the Federal
Advisory Committee Act (FACA), 5 U.S.C. App. ll, applies to “roundtable”
groups that Advocacy convenes for the purpose of conveying and
soliciting information and viewpoints about agency rules and policies.
Based on our review of relevant statutes and legislative history, case law,
regulations, and guidance, and consideration of Advocacy’s views, and
for the reasons detailed below, we conclude that these roundtable groups
are not “advisory committees” within the meaning of FACA and thus
Advocacy is not required to comply with the provisions of that statute.

Background on _ Advocacy is an office established by statute within the Small Business
Advocacy’s Duties and Administration (SBA). 15 U.S.C. § 634a. The office has a separate
Use of Roundtables statutory charter* and, as of 2010, the President must include a separate

line-item appropriation request for Advocacy designated in a separate
Treasury account.’ Advocacy is headed by a Chief Counsel who, among
other things, has statutory authority to appear as an official “friend of the
court” (amicus curiae) in all court challenges to agency regulations in
order to “present his or her views with respect to compliance with [the
Regulatory Flexibility Act, discussed below], the adequacy of the
rulemaking record with respect to smail entities and the effect of the rule
on smail entities.” 5 U.S.C § 612(c). According to recent testimony,
Advocacy is not required to obtain clearance of its comment letters,
publications, and testimony as are other executive branch agencies.‘

Our practice when rendering opinions is to contact the relevant agency and obtain its
legal views on the subject of the request. GAO, Procedures and Practices for Legal
Decisions and Opinions, GAOQ-06-1064SP. (Washington, D.C.: Sept 2006), available at
www.gao.gov/legai/resouces.htmi. We contacted the Chief Counsel for Advocacy who,
through Advocacy’s Director of interagency Affairs, provided us with the agency's views.
Letter from Advocacy to Managing Associate General Counsel, GAO, April 24, 2014
(Advocacy Letter to GAO).

Pub. L. No. 94-305, Title il (1976), codified as amended at 15 U.S.C. §§ 634a ef seq.
Sub. L. No. 111-240 (2010).

‘Testimony of Dr. ‘geant, Chief Counsel for Advocacy, U.S. Small Business
Administration, before the Senate Committee on Smail i and Pp ip
(Apr. 17, 2013).

Page 34 GAO-14-525 Office of Advocacy
765

Appendix Itt: Legal Analysis of the
Applicability of the Federal Advisory
Committee Act to the Office of Advocacy's

Among Advocacy’s duties are serving as “a focal point for the receipt of
complaints, criticisms, and suggestions” concerning federal policies
affecting small businesses; developing proposals for changes in the
policies and procedures of federal agencies that further small business
interests and communicating those proposals to the appropriate federal
agencies; and “represent[ing] the views and interests of small businesses
before other Federal agencies whose policies and activities may affect
smail business.” 15 U.S.C. § 634c. Advocacy also has key responsibilities
and authorities under the Regulatory Flexibility Act (RFA), 5 U.S.C. §§
601 et seq., and under Executive Order 13272 which helps implement the
RFA. The RFA requires Advocacy to assist regulatory agencies during all
stages of the rulemaking process to mitigate the potential adverse impact
of the rules on small entities while achieving their regulatory objectives,
and the Executive Order requires agencies to notify Advocacy of any
proposed rules expected to have a significant economic impact on a
substantial number of small entities and to consider any comments
Advocacy submits on the rule. The RFA and Executive Order both require
agencies to respond to Advocacy comments in their final rules and note
any resulting changes. Advocacy plays a similar role with respect to
certain designated agencies as a member of what are known as
“SBREFA panels.” The Small Business Regulatory Enforcement Fairness
Act of 1996 (SBREFA)® amended the RFA to require the Environmental
Protection Agency, the Occupational Safety and Health Administration,
and the Consumer Financial Protection Bureau to convene panels with
officials from Advocacy, the Office of Management and Budget, and the
rule-writing agency whenever the agencies develop rules for which an
initial regulatory flexibility analysis is required. The panels must develop
information solicited from small entity representatives and other sources
concerning the potential impacts of the agency proposal; consider
alternatives that minimize burdens on smail entities; and prepare a report
with recommendations to the agency head for consideration in the
proposed rule. 5 U.S.C. § 609(b)-(e).

One of the ways that Advocacy fulfills these statutory responsibilities is by
convening roundtable meetings for representatives of small businesses
and government agencies. Advocacy invites roundtable participants,
typically by email, but it is Advocacy's policy to welcome participation by

SPub. L. No.104-121, title Il.

Page 35 GAO-14-525 Office of Advocacy
766

Appendix tit: Legal Anatysis of the
Appilcabillty of the Federal Advisory
Committee Act to the Office of Advocacy’s

any interested party other than the press.® According to Advocacy, it
hosted 32 roundtables in Fiscal Year 2012 and 21 roundtables in Fiscal
Year 2013.’ The roundtables typically focus on specific proposed agency
regulations and stakeholders provide information about the potential
economic impacts of the proposal and identify less burdensome
alternatives. Advocacy often uses the results of these roundtables (and
other information) as the basis of formal comment letters it submits to the
proposing agency, for example disagreeing with the agency's impact
analysis and urging less burdensome alternatives; it submitted 26 such
letters in FY 2013° to which agencies must, by statute, respond. 5 U.S.C.
§ 604(a)({3). In Advocacy’s view, the concerns articulated by small
business representatives at roundtables are influential; for example,
according to Advocacy, after a roundtable regarding the Employee
Benefits Security Administration’s guidance on brokerage windows, the
Administration issued revised guidance addressing the smal! business
concerns. See Report on the Regulatory Flexibility Act, FY 2012, above,
at 7. And after attending an Advocacy roundtable that addressed
proposed revisions to Occupational Safety and Health Administration
(‘OSHA’) noise standards, OSHA withdrew the rule and pledged to
conduct additional stakeholder outreach before proceeding. See Report
on the Regulatory Flexibility Act, FY 2011 at 4.

Applicability of the Federal
Advisory Committee Act

FACA establishes requirements for “advisory committees” to the federal
government, defined as relevant here as “any committee, . . . panel, task
force, or other similar group . . . which is established or utilized by one or
more agencies, in the interest of obtaining advice or recommendations for
. . one or more agencies or officers of the Federal Government. . .." 5
U.S.C. App. II, § 3(2). Congress enacted FACA in 1972 “to enhance the
public accountability of advisory committees and to reduce wasteful
expenditures” that “result only in worthless committee meetings and

aq y roundtable invitations and agi state in part: “Roundtable meetings are
open to all i Pp with the ion of the press, in order to facilitate an
open and frank discussion about small busii lated issues, Agendas and

ions are avai to ail, i ing the press. Anyone who wouid like to receive

rot ie) or pi , OF
forward such requests to [Advocacy}.”

TSBA Office of Advocacy, Report on the Regulatory Flexibility Act, FY 2012 at 4; Report
on the Regulatory Flexibility Act, FY 2013, ati.

®Report on the Regulatory Flexibility Act, FY 2013, supra, at i.

d in the regular distribution, should

Page 36 GAO-14-525 Office of Advocacy
767

Appendix Hl: Legal Analysis of the
Applicability of the Federal Advisory
Committee Act to the Office of Advocacy’s

biased proposais”. Pub. Citizen v. U.S, Dep't of Justice, 491 U.S. 440,
459 (1989). Similarly, FACA’s purpose was to “ensure that new advisory
committees be established only when essential [;] . . . that their creation,
operation, and duration be subject to uniform standards and procedures;
that . . . the public remain apprised of their existence, activities, and cost;
and that their work be exclusively advisory in nature.” Id. at 446.

For advisory committees covered by the act, FACA requires, among other
things, that their meetings be open to the public; that timely notice of
meetings be published in the Federal Register; that interested parties be
allowed to attend, appear before, or file statements with the advisory
committee; and that detailed minutes of advisory committee meetings be
kept. In addition, for advisory committees established by agency heads,
the agency must, as applicable, ensure that committee membership is
fairly balanced in terms of points of view represented and functions to be
performed and ensure that the recommendations of the committee are
not inappropriately influenced by the agency or any special interest but
rather reflect the committee’s independent judgment. 5 U.S.C. App. Il, §
10. Because Advocacy does not apply these FACA requirements to its
roundtables, we examined whether the statute applies to these groups
and their activities.

1. Is Advocacy a FACA “Agency”?

As noted above, whether Advocacy roundtables are advisory committees
subject to FACA depends in part on whether they have been “established
or utilized by one or more agencies . . ..” (emphasis added). Thus as a
threshold issue, we examine whether Advocacy is an “agency” for
purposes of FACA.

FACA defines “agency” by incorporating the term's general definition in
the Administrative Procedure Act (APA). 5 U.S.C. App. Il, § 3(3). With
exclusions not relevant here, the APA defines “agency” as “each authority
of the Government of the United States, whether or not it is within or
subject to review by another agency .. ..” 5 U.S.C. § 551(1).

Advocacy believes it is an “agency” for purposes of FACA. Citing the
foregoing APA definition, Advocacy states that it is an “authority of the
Government of the United States” and not covered by any of the
exclusions. Advocacy Letter to GAO at 2.

Yet as the courts have recognized, “the law on the simple question of
what is an [APA] agency is quite complex.” Lee Constr. Co. v. Federal

Page 37 GAO-14-525 Office of Advocacy
768

Appendix lit: Legal Analysis of the
Applicability of the Federal Advisory
Committee Act to the Office of Advocacy’s
Roundtables

Reserve Bank, 558 F. Supp. 165, 172 (D. Md. 1982). Likewise, the courts
have acknowledged that “[a]ny general definition [of “agency” under the
APA] can be of only limited utility . . . [when] confronted with one of the
myriad organizational arrangements for getting the business of the
government done. .. .The unavoidable fact is that each new arrangement
must be examined anew and in its own context.” Washington Research
Project, Inc. v. HEW, 504 F.2d 238, 245-46 (D.C. Cir.1974), cert. denied,
421 U.S. 963 (1975)(citations omitted).

Courts have taken somewhat different approaches to what constitutes an
“agency” under the APA. The seminal case is Soucie v. David, 448 F.2d
1067 (D.C. Cir. 1971), which involved what was then called the Executive
Office of the President's Office of Science and Technology (OST). The
lawsuit sought the release of an OST document under the Freedom of
Information Act (FOIA). Because the FOIA and APA definitions of
“agency” were identical at the time of the lawsuit, the court looked to
interpretations of the APA in determining whether OST was an “agency”
under FOIA. The court found that while the meaning of “agency” under
the APA was “not entirely clear,” it “apparently confers agency status on
any administrative unit with substantial independent authority in the
exercise of specific functions.” 448 F.2d at 1073 (emphasis added).
Because OST evaluated federal science programs previously evaluated
by the National Science Foundation, in addition to its non-’independent”
responsibilities in advising and assisting the President, the court found
OST had “substantial independent authority” and “must be regarded as
an agency subject to the APA and [FOIA].” Id. at 1075.

The court in McKinney v. Caldera, 141 F. Supp. 2d 25 (D.D.C. 2001),
applied the Soucie test and found that the office of the Judge Advocate
General of the Army (JAG) was not an APA “agency” because it lacked
“substantial independent authority.” Although JAG supervised the Army’s
military justice system, performed appellate review of court martial trials,
and furnished legal services, the court focused on the fact that JAG's
duties flowed from the authority of the Secretary of the Army. This
rendered JAG insufficiently independent, the court ruled, notwithstanding
that the APA contemplates the possibility of an “agency” within an
“agency.”

Other courts have framed the APA “agency” definition slightly differently,
looking to whether an entity can take “final and binding action.” This
standard is based in part on the Soucie “substantial independent
authority” test but also on the APA’s legislative history indicating
Congress intended covered agencies to have “final and binding” legal

Page 38 GAO-14-525 Office of Advocacy
769

Appendix ill: Legat Analysis of the
Applicability of the Federal Advisory
Committee Act to the Office of Advocacy's
Roundtables

authority. in Dong v. Smithsonian Institution, 125 F.3d 877 (D.C. Cir.
1997), cert. denied, 524 U.S. 922 (1998), for example, the court looked to
whether the Smithsonian Institution was:

“a part of government which is generally i fent in the ise of fits} functions and .
. . by law has authority to take final and binding action affecting the rights and obligations
of individuals, particularly by the istic p d of rule-making and
adjudication.”

id. at 881 (emphasis added). The court found that the Smithsonian was
not an APA “agency” under this standard because while it exercised
authority, the authority was not sufficiently “substantial.” Although the
Smithsonian is closely linked with the federal government, receives
federal funding, has certain police powers to protect its physical plant,
and publishes regulations in the Code of Federal Regulations, the court
noted that it does not make binding rules of general application,
determine rights and duties through adjudications, issue orders, or
perform regulatory functions.®

Still other courts determining APA agency status have focused on
whether an entity is one of the “centers of gravity” in the exercise of
administrative power “where substantial ‘powers to act’ . . .are vested”
(see, e.g., Lee Constr. Co., above, 558 F. Supp. at 174, holding Federal
Reserve Bank of Richmond was APA agency based on substantial
delegated decision-making authority from Federal Reserve System Board
of Governors), or whether the entity has “authority in law to make
decisions” (see, e.g., Washington Research Project, Inc. v. HEW, above,
504 F.2d at 248, holding that the Department of Health, Education, and
Welfare (HEW) peer review groups for grant applications were not APA
agencies because they only recommended grants to a National Institutes
of Health entity, which, in turn, made recommendations to the HEW
Secretary).

Dong involved whether the Smithsonian was an “agency” under the Privacy Act, which in
turn adopts the definition of “agency” under FOIA. See 5 U.S.C. § 552a(a){1). FOIA
incorporated the APA “agency” definition until 1974, at which point Congress broadened
the core APA “agency” definition for FOIA purposes, but the portion of the Dong court’s
analysis cited here focuses on whether the Smithsonian was agency under the pre-1974
version of the APA.

Page 39 GAO-14-525 Office of Advocacy
770

Appendix it: Legal Analysis of the
Applicablilty of the Federal Advisory
Committee Act to the Office of Advocacy’s
Roundtables

Applying these authorities and considering Advocacy's views, we
conclude that Advocacy is an “agency” under the APA, and thus under
FACA, because it possesses the requisite “substantial independent
authority.” First, it acts with independence. Although Advocacy is an
“agency” within an “agency” (SBA), as noted, it has distinct statutory
authorities and responsibilities and a separate statutory charter; a
separate line-item budget request; its head can appear in court appeals to
speak to the rulemaking agency’s compliance with the RFA; and it does
not have to obtain clearance of its comments and testimony. Unlike JAG
in the McKinney case, above, which the court found was not an “agency”
because its duties derived from the Army Secretary, the Chief Counsel's
duties are related to but distinct from the SBA Administrator.

Second, Advocacy’s authorities and duties under its organic statute, the
RFA, and Executive Order 13272 are “substantial.” As noted, it is
responsible among other things for identifying and advocating the views
and concerns of small entities throughout the Executive Branch and for
developing proposed changes in the policies and procedures of federal
agencies in order to further the interests of small business. Although it
does not issue regulations, conduct adjudications, or otherwise take
traditional “final and binding action,” its views and recommendations
must, by law, be accorded considerable weight. Taken as a whole, we
believe it has substantial authority under the case law.

2. Are Advocacy’s Roundtable Groups FACA “Advisory Committees”?

Having found that Advocacy is a FACA “agency,” we examine whether its
roundtables are FACA “advisory committees.” As noted, FACA defines
this term in part as “any committee, . . . panel, task force, or other similar
group . . . which is established or utilized by one or more agencies, in the
interest of obtaining advice or recommendations for .. . one or more
agencies or officers of the Federal Government. . .."5 U.S.C. App. Il, §
3(2). Because of Advocacy’s particular statutory responsibilities, notably
to identify and communicate concerns of smail businesses and entities,
Congress clearly contemplated that Advocacy would have a close
relationship with small business. Its mission virtually requires consultation
with these entities to obtain data, opinions and possible advice, and one
way it has chosen to do this is by holding roundtable meetings.

Page 40 GAO-14-525 Office of Advocacy
771

Appendix fil: Legal Analysis of the
Applicability of the Federal Advisory
Committees Act te the Office of Advocacy's
Roundtables

In Advocacy’s view, its roundtables are not FACA advisory committees. It
believes the roundtables help it achieve its mission;"° indeed, Advocacy
maintains that without the discussions that occur at roundtables, its
“ability to fulfill its .. . statutory obligations would be severely curtailed.”
Advocacy Letter to GAO at 2. Explaining its position that these activities
do not trigger FACA, it states:

“[a] though the definition [in] FACA is broad, FACA does not apply to all committees,
meetings, or groups. . . . In enacting FACA, Congress was concerned with formally
organized advisory committees which the President or an executive department or official

ji to make ions on identified governmental policy for which specific
advice was sought. It was not intended to apply to all amorphous, ad hoc group meetings;
only groups having some sort of established structure and defined purpose constitute
advisory committees within the act.”

Advocacy Letter to GAO at 3 (citations omitted).

We agree with Advocacy that under the case law, not every group that
provides information or advice to a federal agency is a FACA “advisory
committee.” Although no single aspect of a group's creation, structure or
activities is controlling, most courts have focused on the formality,
structure, and continuity of the group and whether the group is brought
together to provide advice or recommendations as group rather than as a
collection of individuals. As the Supreme Court explained in Public

according to Adv “Ad\ holds nu roundtable di ions with small
business stakeholders to educate them about ig legal and
across the federal government and discuss their effect on small entities. Roundtable

Ice varies from 9 to ing, and staff encourages wide public participation
by encouraging invitees to forward roundtable invitations to interested parties to attend or
to call in if in-p is not practi On many i officials from
federal agencies and Cong! attend Adi y roundtables to provide information
regarding agency activities and approaches and to pose questions to small entities and
their representatives directly. Roundtables on specific topics also provide a platform for

smail businesses to provide their views on specific practi policies and
pre by various g R also serve to inform
Advocacy staff of a wide \ variety of practical and i ig smal bus

might be facing as a result of federal policies, Ad
useful for the office because they allow staff to witness rand foster dialogue among various

ig small i their and public
interest groups. These conversations often shed light on what are usually complex
that dese on often very short notice, by Advocacy

staff in their own evaluation oft the | impact of regulations on small entities.”

Advocacy Letter to GAO at 1-2.

Page 41 GAO-14-525 Office of Advocacy
772

Appendix lll: Legal Analysis of the
Applicability of the Federal

Committee Act to the Office of Advocacy’s
Roundtables

Citizen, above, Congress did not design FACA to cover every formal or
informal consultation between a government agency and a group
rendering advice; such a literalistic reading would cover “far more groups
and arrangements than Congress could conceivably have intended.” 491
US. at 464-65.

Several early cases addressed whether an informal or “ad hoc” group
such as Advocacy's roundtables was an advisory committee. The court in
Food Chemical News v. Davis, 378 F. Supp. 1048 (D.D.C. 1974),
considered whether two “informal” meetings of distilled spirits industry
representatives, convened by the head of the Bureau of Alcohol, Tobacco
and Firearms (BATF) to obtain advice on draft regulatory amendments,
were subject to FACA. Noting that the act’s purpose was to control the
advisory committee process and to open to public scrutiny the manner in
which government agencies obtain advice from private individuals, the
court held it was “undisputed that [BATF] utilized an ad hoc committee of
industry representatives in order to obtain advice. Such a relationship . . .
clearly comes within the terms of . . . [FACA].” Id. at 1051.

The following year, the same court considered whether bi-weekly
meetings held at the White House and attended by selected groups
invited by the President’s Assistant for Public Liaison were subject to
FACA. In Nader v. Baroody, 396 F.Supp. 1231 (D.D.C. 1975), the court
concluded that the groups were not advisory committees, relying on two
characteristics of the meetings: the absence of a specific request for
advice on a matter of government policy and the lack of formal
organization or continuity.

The Second Circuit Court of Appeals considered Food Chemical News
and Nader in National Nutritional Foods Association v. Califano, 603 F. 2d
327 (2d Cir. 1979). The Califano court determined that FACA applied to a
single meeting between six officials from the Food and Drug
Administration and six obesity experts “to assist the FDA in selecting the
best course of action ‘for regulating the production and promotion of
[weight reduction products]. . . ." Agreeing with the rulings of both
previous cases, the court found the facts of Food Chemical News to be
closer to the case before it because FDA had called on specific
individuals to provide group advice on a particular proposed regulation
and relied on the group advice.

The element of “group advice” continued to play a key role in the seminal

case of Association of Am. Physicians and Surgeons, Inc. v. Clinton, 997
F. 2d 898 (D.C. Cir. 1993) (AAPS), involving the Clinton Administration's

Page 42 GAO-14-525 Office of Advocacy
773

Appendix HE: Lega! Analysis of the
Applicability of the Federal Advisory
Committee Act to the Office of Advocacy’s
Roundtabies

Health Care Reform Task Force. The D.C. Circuit Court of Appeals held
in AAPS that “a group is a FACA advisory committee when it is asked to
tender advice or recommendations, as a group, and not as a collection of
individuals.” Id. at 913 (emphasis in original). “[A]n important factor in
determining the presence of an advisory committee [is] the formality and
structure of the group,” the court held, laying out three criteria needed to
implicate FACA: “an organized structure, a fixed membership, and a
specific purpose.” Id. at 914. Characterizing variation in these factors as a
continuum, the court explained that at one end of the continuum is a
“formal group of a limited number of private citizens who are brought
together to give publicized advice as a group"—this group is covered—
while at the other end of the continuum is “an unstructured arrangement
in which the government seeks advice from what is only a collection of
individuals who do not significantly interact with one another.” Id, at 915."
See also Freedom Watch v. Obama, 807 F. Supp. 2d 28 (D.D.C. 2011)
(applying AAPS criteria; finding colorable claim of FACA coverage based
on fixed group membership and formation for specific policy purpose);
Citizens for Responsibility and Ethics in Washington v. Leavitt, 577 F.
Supp. 2d 427, 432 (D.D.C. 2008) (same; finding no FACA coverage
where “[t]he groups had no formal organizational structure ... . Attendees
conveyed their own opinions regarding their individual areas of expertise”
and “[n]o group report or other collaborative work product was created.”).
But see Aluminum Co. of America v. National Marine Fisheries Service,
92 F. 3d 902 (6th Cir. 1996) (cautioning against rigid application of AAPS
criteria).

Implementing regulations issued by the General Services Administration
(GSA), the agency responsible for administering FACA government-wide,
rely in part on this case law in defining what constitutes a FACA advisory
committee. In issuing its final FACA management rule in 2001, GSA
“recognize[d] that the broad definition in the Act of an ‘advisory
committee’ might be interpreted to extend coverage by the Act to any
gathering of two or more persons from whom . . . Federal officers or
agencies seek advice or recommendations. However, in the cases
discussed above, the courts have rejected such a broad reading . . . .” 66
Fed. Reg. 37728, 37730 (July 19, 2001). GSA’s regulations therefore
exempt from FACA regulation “[ajny group that meets with Federal

“The AAPS court the case to ether a particular working group of
President Clinton's Health Care Reform Task Force was a FACA advisory committee
under these criteria.

Page 43 GAO-14-525 Office of Advocacy
774

Appendix ll: Legat Analysis of the
Applicability of the Federal Advisory
Committee Act to the Office of Advocacy’s
Roundtables

Official(s), including a public meeting, where advice is sought from the
attendees on an individual basis and not from the group as a whole. .. .”
41 C.F.R. § 102-3.40(e). GSA regulations further state that development
of consensus among meeting participants does not in itself convert the
group to a FACA committee, nor does the presence of trade association
or other organization representatives affect whether advice is obtained
“on an individual basis.” 41 C.F.R. Parts 102-3, Subpart A, App. A, Key
Points and Principles ll, lil.

Applying these authorities and considering Advocacy’s views, we
conclude that Advocacy's roundtables are not FACA advisory
committees. First, we recognize that roundtable participants are not
random attendees but rather invited representatives of a particular
“group"—the small business community—-whose concerns and
perspective it is Advocacy’s very mission to identify and advocate.’? As
noted, however, Advocacy invites anyone (except the press) with an
expressed desire to attend and thus there is no structured or fixed
membership in a “roundtable group.”

Nor is group consensus sought from roundtable participants. Under the
standards in AAPS, 603 F.2d at 913, the group’s activities are not
expected to, and do not appear to, benefit from the interaction among the
participants. Rather, as contemplated by the GSA regulations, information
is solicited from participants as individuals (including individuals
representing trade associations), although a consensus may develop.
See 41 C.F.R. Part 102-3, Subpart A, App. A, Key Point ll (‘The
development of consensus among all or some of the attendees at a public
or similar forum does not automatically invoke FACA.”). As in Leavitt,
above, no group report or other collaborative work product is created. And
as in American Society of Dermatology v. Shalala, 962 F. Supp. 141
(D.D.C 1996), there is no attempt to create consensus among participants
either overall or on any aspects of the issue under consideration. See id.
at 148 (among the “main factors leading to the Court's determination that
the panels fall into the non-advisory committee end of the [AAPS]
continuum fis] . . . the absence of any attempt to achieve consensus.”).

as st ized in recent testimony, Ad y was “created . . . to be a voice for small
business within the federal government. . . [and] advances the views, concerms, and

i of small busi ...” Testi y of Dr. Winslow Sargeant, Chief Counsel for
Ad y, U.S. Small i Admini ion, before the House Committee on Small
Busi L ittee on | ions, Oversight and Regulations (Mar. 14, 2013).

Page 44 GAO-14-525 Office of Advocacy
775

Appendix iii: Legal Analysis of the
Applicabillty of the Federal Advisory
Committee Act to the Office of Advocacy's

Nor does Advocacy’s submission of comment letters based on
information obtained at roundtables establish that it convened the
roundtable to obtain a group consensus. While Advocacy's position in a
comment letter may represent a consensus of views expressed at a
roundtable, that consensus appears to be a function of the fact that many
of the participants, as small entities, share common concerns.

Finally, according to Advocacy, it only obtains data and information from
roundtable participants, not policy advice or recommendations. It is
Advocacy itself that develops policy recommendations, it told us, based
on information it obtains at roundtables and elsewhere and using its own
judgment and expertise. Even if advice and recommendations were
offered at roundtables, however (a smail business representative
recommending a regulatory policy change based on its impact on small
business, for example), in our view, this would not outweigh the other
factors indicating that the roundtables are not covered advisory
committees. '*

Conclusions

Advocacy is an “agency” under FACA first because it meets the statutory
definition of this term in FACA and the Administrative Procedure Act
incorporated by reference: it is an “authority of the Government of the
United States, whether or not it is within or subject to review by another
agency” and not subject to statutory exemption. In addition, Advocacy has
the type of “substantial independent authority” and other indicia of
“agency” status that courts interpreting the APA definition have required.
However, Advocacy's roundtable groups are not FACA “advisory
committees” because they do not have an organized or fixed structure;
there is no attempt to reach consensus about an agency regulation or
policy but instead viewpoints are sought from individual participants; and
it is only data and information, according to Advocacy, rather than advice
or policy recommendations, that participants provide.

BB we conclude that A 'S les are not FACA advisory committees
for the reasons discussed here, we did not determine whether the additional FACA
element was met of the roundtables being “established or utilized by" Advocacy. 5 U.S.C.
App. ll, § 3(2).

Page 45 GAO-14-525 Office of Advocacy
776

Appendix IV: GAO Contact and Staff
Acknowledgments

GAO Contact Cindy Brown Barnes (202-512-8678), brownbarnesc@gao.gov.

Staff In addition to the contact named above, Kay Kuhiman and Triana McNeil
(Assistant Directors), Kristeen McLain (Analyst-in-Charge), Emily

Acknowledgments Chalmers, William Chatlos, John McGrail, Lauren Nunnally, Roberto
Pinero, Jena Sinkfield, Jack Wang, and Carrie Watkins made key
contributions to this report.

(260738) Page 46 GAO-14-526 Office of Advocacy
777

GAO’s Mission

The Government Accountability Office, the audit, evaluation, and
investigative arm of Congress, exists to support Congress in meeting its
constitutional responsibilities and to help improve the performance and
accountability of the federal government for the American people. GAO
examines the use of public funds; evaluates federal programs and
policies; and provides analyses, recommendations, and other assistance
to help Congress make informed oversight, policy, and funding decisions.
GAO’s commitment to good government is reflected in its core values of
accountability, integrity, and reliability.

Obtaining Copies of
GAO Reports and
Testimony

The fastest and easiest way to obtain copies of GAO documents at no
cost is through GAO’s website (http:/Avww.gao.gov). Each weekday
afternoon, GAO posts on its website newly released reports, testimony,
and correspondence. To have GAO e-mail you a list of newly posted
products, go to http:/Avww.gao.gov and select “E-mail Updates.”

Order by Phone

The price of each GAO publication reflects GAO's actual cost of
production and distribution and depends on the number of pages in the
publication and whether the publication is printed in color or black and
white. Pricing and ordering information is posted on GAO's website,

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537.

Orders may be paid for using American Express, Discover Card,
MasterCard, Visa, check, or money order. Call for additional information.

Connect with GAO

Connect with GAO on Facebook, Flickr, Twitter, and YouTube.
Subscribe to our RSS Feeds or E-mail Updates. Listen to our Podcasts.
Visit GAO on the web at www.gao.gov.

To Report Fraud,
Waste, and Abuse in
Federal Programs

Contact:

Website: http:/Awww.gao.gov/fraudnet/fraudnet.htm
E-mail: fraudnet@gao.gov
Automated answering system: (800) 424-5454 or (202) 512-7470

Congressional
Relations

Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-
4400, U.S. Government Accountability Office, 441 G Street NW, Room
7125, Washington, DC 20548

Public Affairs

Chuck Young, Managing Director, younge1@gao.gov, (202) 512-4800
U.S. Government Accountability Office, 441 G Street NW, Room 7149
Washington, DC 20548

Please Print on Recycied Paper.
778

FREEDOM
FIGHTERS

February 14, 2024

The Honorable Roger Williams The Honorable Nydia Velazquez
Chairman Ranking Member

Committee on Small Business Committee on Small Business
U.S. House of Representatives U.S. House of Representatives
Washington, D.C. 20515 Washington, D.C. 20515

Re: Statement for the Record Before the United States House of Representatives
Committee on Small Business, “Burdensome Regulations: Examining the Impact of EPA
Regulations on Main Street” ,

Dear Chairman Williams and Ranking Member Velazquez:

JCN applauds Chairman Williams for holding this important hearing exploring the unique and
detrimental impact that regulations — particularly environmental regulations -- have on small
businesses across America.

My name is Alfredo Ortiz and { serve as Chief Executive Officer of the Job Creators Network.

JCN is a nonpartisan organization founded by entrepreneurs who believe that many
government policies are getting in the way of the economic freedom that helped make this
country prosperous.

JCN provides business leaders and entrepreneurs with the tools to become the voice of free
enterprise in the media, in Congress, in state capitals, in their communities, and their
workplaces — allowing them to hold politicians accountable to job creators and their employees.

According to the U.S. Small Business Administration’s Office of Advocacy small businesses
employ almost half — 46.4 percent — of America’s private sector employees. Truly America’s job
creators, small businesses accounted for 62.7 percent of net new jobs from 1995 to 2021.?
According to the JCN Smail Business IQ poll, an index tracking overall small business optimism,
89 percent of all small business owners have fewer than 20 employees.? For these businesses,
which are the lifeblood of our nation’s economy, federal regulation is an anchor that impedes
their ability to grow their business and create jobs.

1.5, Small Business Administration, Office of Advocacy, “What's New With Small Business?” (March 2023).
3 john McLaughlin and Scott Rasmussen, “December 2023 Job Creators Network Foundation Small Business

Monthly Poll,” at 6.
779

FREEDOM
GHTERS

From the day President Biden took office through February 9 federal agencies have issued 774
final rules at a cost of $451.7 billion, and 286.7 million paperwork hours.‘ These numbers are
mind-numbing and hard for the average person to process. But for America’s small businesses,
the costs of complying with federal regulations are felt daily in their businesses.

According to a recent study, businesses with fewer than 50 employees pay $14,700 per
employee to comply with federal regulations as compared to $12,200 per employee for
businesses with 100 or more employees.> When it comes to environmental regulation, the
difference in regulatory compliance costs is significantly greater between small and large
companies, with businesses employing less than 50 employees paying $6,000 per employee
while businesses with 100 or more employees pay $1,800 per employee.®

Congress recognized the disproportionate impact of regulations on small businesses by enacting
the Regulatory Flexibility Act of 1980 and then passing the Small Business Regulatory
Enforcement and Fairness Act of 1996, which amended the RFA to close certain loopholes and
ensure that federal agencies properly consider the costs and impacts of a proposed regulation
on small business before finalizing it. ,

As this Committee has demonstrated through its work, time and again, federal agencies have
failed to comply with the letter and spirit of the RFA to the detriment of millions of small
business owners across the country.

For this reason, JCN supports H.R. 7198, the Prove It Act, bipartisan legislation recently
introduced by Representatives Brad Finstad, Yadira Caraveo, and Nathaniel Moran that would
rein in executive overreach by bolstering existing law that federal agencies have been side-
stepping at the expense of small businesses.

Specifically, their bill would force federal regulators to follow the letter and spirit of the RFA and
consider the costs new government red tape would have on Main Street businesses. It would
ensure small businesses and organizations representing their interests have a seat at the table
when government regulators are weighing whether a proposed rule would have a negative
impact on entrepreneurs. And it would empower small businesses and their defenders to
challenge certifications by federal agencies that claim a proposed rule would not significantly
impact a substantial number of small businesses.

‘Dan Goldbeck, Week i in Regulation, Regulatory Costs Spike Back Up American Action Forum, Feb. 12, 2024
fi : (website last visited

February 13, 2024).

5 Nicole V, Crain and W. Mark Crain, “The Cost of Federal Regulation to the U.S. Economy, Manufacturing, and Small
usiness,” A Study Conducted for the National Association of Manufacturers, at 4, October 2023.

Business,”
780

FREEDOM
FIGHTERS

Small businesses would subsequently be exempt from any rule in which an agency fails to
meaningfully participate in the petition and review process.

The Prove it Act would fulfill a key pillar of Job Creators Network’s American Small Business
Prosperity Plan, an eight-point policy playbook to jumpstart the small business economy.

Small business regulatory protections are in dire need of restoration. Enactment of The Prove It
Act would be a step in the right direction and we urge the Committee to consider and pass this
important legislation.

Sincerely,

Alfredo Ortiz
Chief Executive Officer
Job Creators Network
781

Regulations, Small Business and Environmental Justice
House Committee on Small Business, written testimony

Lemir Teron, PhD
Associate Professor
Howard University
Department of Earth, Environment & Equity

There should be little doubt that small businesses thrive when environmental regulations are conceived and
developed in an atmosphere of transparency and in which proper safeguards and enforcement means are
enacted. Strong regulations enable small firms to operate on a more even playing field with large business
that can often chalk up lax environmental regulations and the “right to pollute” as a standard process within
the business cycle. With smart regulation, not only are ecologies strengthened, but so are conditions for
labor, local economies and the overall health of communities.

There are a cadre of Federal resources devoted to aid small firms’ compliance with state and Federal
environmental statutes, including the Office of Small and Disadvantaged Business Utilization, Compliance
Assessment Centers and a host of other Federal and state level resources. This is further undergirded by
the legal framework designed to aid small businesses and help them shape the regulatory making processes
enacted under the Small Business Regulatory Enforcement Fairness Act and the Regulatory Flexibility Act,
respectively. When regulatory policies are accessible, and supporting bodies and resources are adequately
funded, the regulatory climate consequently benefits everyone.

Environmental regulations make the marketplace safter for us all; not only do they increase confidence that
products are safe for users, but also help ensure that products and services are manufactured, developed and
delivered in a manner that’s beneficial for workers and that the communities in which they are processed
and consumed in are protected. Strong standards also help in the competitive space amongst firms, as
businesses -- small and large alike -- can act with increased security knowing they are insulated from
competitors who’d seek to reduce cost through dangerous methods, engage in excessive polluting or cutting
corners which may expose workers to unsafe conditions

Strong regulations are crucial in protecting marginalized communities from being further harmed by
industrial pollution. That the consequences of environmental pollution have acted within the context of the
long and brutal legacy of environmental racism and inequality is well documented. The uneven
vulnerability to air pollution and acts of “super” polluters -- those industrial polluters responsible for a
lion’s share of air pollution -- exemplifies this. It should be no surprise, to anyone, on the committee or
otherwise, as to whose neighborhoods carry the burden for these discharges: disproportionately African
American and low income communities. Recent research has revealed that the environmental and public
health consequence of large polluting facilities exposes frontline communities, which are disproportionately
composed of African American and other groups that have historically been socially, politically and
economically marginalized, to dangerous levels of pollution that undermine their life quality and public
health on a daily basis. Additionally, these communities carry steep energy burdens (the percent of take
home pay that goes towards heating and cooling needs). Not only do labor from these communities often
bear the brunt of dangerous work, in a bonanza of insufficient environmental protections, these communities
become clustered with suites of polluting facilities that expose the young and old, impoverished and well
off, to life harming substances. Though cliché, it’s disingenuous and inaccurate to advance tropes regarding
regulations being designed to target or disrupt small firms. Of the 20,000+ industrial facilities that have
EPA reporting responsibilities, a third of both toxic releases and GHG emissions originate from only about
100 firms, and the list is dominated by large firms which are amongst the most powerful corporations in
the world, not the small businesses that anti-regulation advocates feign.
782

Strong and clear environmental regulations center healthy environments, human livelihoods and dignity
and advance the interests of the nation’s economic engine: labor. Notwithstanding claims espousing
otherwise, the threat to US workers and small businesses aren’t imposed by environmental regulations, but
the absence of them -- which undermines both public and environmental health. Anti-regulatory activity
compromises worker safety, and has historically been driven by the interests of large firms. In a democratic,
just and moral society, our regulatory environment shouldn’t subsidize harmful actions of the large and
powerful under the illusory cloak of protecting small business.

What happens in the absence of regulations? And who benefits from operating in an anti-regulatory
climate? It’s certainly not those environmental justice communities, cited on the frontlines of polluting
industries. Nor is it workers, whose safety gets compromised when the absence of strong regulation and
safety measures makes them expendable. Mostly benefiting from an anti-regulatory and safety
environment, are large firms and their related interests, the control and management of which are often
based and far removed from the local communities that are most directly impacted from industrial pollution
which regulations are designed to protect against.

While history is filled with those that proclaim the disastrous impacts of industry harming and job ‘killing’
regulation, the historical record doesn’t bear this out. Prominent examples abound. Notwithstanding those
that crusaded against car safety measures, automobile safety efforts save innumerable lives annually, and
have spurred innovations which ultimately help the auto industry and small firms through indirect and
induced job growth. More recently, dissenting voices have railed against energy sector regulation which
decreases pollution levels and clean air in power plants: not only do local airsheds in fenceline communities
improve with regulation, lessening incidents of cancer and respiratory illness, but controls also help stave
off climate change Furthermore, energy efficiency and the transition to renewable energy technologies all
increase opportunities for energy independence, economic development and local autonomy. Why is it that
many of those who seemingly espouse those ideals, under the guise of anti-regulation, often fight against
the clearest pathways towards them? The irony abounds.

It’s critical, for the sake of workers, vulnerable communities and small businesses to resist those voices that
dangerously oppose any and all calls for environmental regulations which champion the right to pollute
using the shield of being small business friendly

There is reason to be, cautiously, hopeful. Environmental regulations, which not only safeguard
communities and workers also spur innovation, workforce and economic development. And when
operating in concert with targeted efforts to address economic disparities prevalent in marginalized
communities, such as the Justice40 initiative, and its commitment of providing substantial environmental
and climate programming resources and benefits to ‘disadvantaged’ communities, can mean massive
economic, health and environmental gains for these communities, that ultimately benefit all of society. As
the EPA further concentrates its efforts to combat climate change and environmental inequality, the
opportunity for an energy transition, that is more locally controlled, just and which advances the interests
of small business and local communities is substantial. Recent and projected job growth in the renewable
energy sector provides a clear vision as to what this can look like. Groups like Climate Jobs New York , an
alliance of over 2 million labor union members whose dual focus is aligned around work that confronts
climate change while combating economic inequality offer a template of what a just and equitable
renewable energy economy can aspire to.

The US will continue to push forward efforts to combat climate change and a host of related threats ranging
from extreme heat.and superstorms, vulnerable agriculture and food systems, flood-prone cities and energy
system vulnerability. Strong regulations that work in concert with renewable energy transitions, and that
783

centers labor and communities that have suffered due to long histories of inequality, are vital in moving the
nation and planet forward. As regulations protect the lifeblood of small firms, workers, communities,
economies and environments, all of us are better for it. As is the nation.
784

Congress of the United States
Washington, BE 20515

July 17, 2023

The Honorable Michael S. Regan

Administrator

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue NW, Mail Stop 1301A
Washington, DC 20460

Dear Administrator Regan,

We write as Members of Congress who represent—or are otherwise concerned about—
communities around the country impacted by dangerous levels of ethylene oxide (EtO)
emissions. In 2019, many of us formed the bipartisan U.S. House of Representatives EtO Task
Force to advocate for tightening emissions standards for EtO sterilization facilities. In the Senate,
we have consistently encouraged the agency to share critical public health information with
communities located near EtO facilities, as well as to strengthen public health protections
through regulatory action. We all welcome the U.S. Environmental Protection Agency’s (EPA)
recently proposed Clean Air Act rule strengthening emissions monitoring and control
requirements at EtO sterilization facilities, and we appreciate your engagement with the EtO
Task Force and other concerned Members as you developed the proposed rule. As many of us
have worked on this issue for years and represent impacted communities, we write to provide
comments on the proposal.

First, we appreciate EPA implementing many of the EtO Task Force’s requests throughout the
process of developing the proposed rule. We especially commend EPA for putting public health
at the forefront of its considerations by conducting a residual risk review to support the proposal
—in line with the May 2021 report by EPA’s Office of Inspector General that made the same
recommendation. We also appreciate EPA’s efforts to engage affected communities as it
developed the proposed rule, and we urge EPA to make community engagement a core
component of its process as it finalizes and implements the rule. For example, including in the
final rule the proposed requirement for sterilizers to obtain a Title V operating permit would
ensure that affected communities can comment on compliance.

We recognize that EPA aims to address both fugitive and stack emissions in its proposed rule,
both of which have been demonstrated to contribute pollution to our communities. However, we
would like to reiterate our position that fugitive emissions cannot be confidently accounted for
without a requirement for ambient air monitoring. As we saw in Willowbrook, IL, it was only
after ambient air monitoring was conducted that we fully understood the significant role fugitive
emissions played in community exposure. Given strong evidence that fence-line monitoring is a
proven method for verifying the effectiveness of emission control equipment and detecting
fugitive emissions, we encourage you to include requirements for fence-line monitoring in the
final rule.

We have also heard concern from our community stakeholders that offsite storage warehouses
785

are excluded from regulation under the proposed rule. We share the concern that this loophole
could create a perverse incentive for industry to use these offsite facilities as secondary aeration
rooms for off-gassing EtO-sterilized medical equipment — skirting requirements for health-
protective emission controls and monitoring, while failing to provide a clear picture of the extent
of EtO being emitted into communities. Warehouse facilities have been a major source of
fugitive emissions at EtO sites in Georgia. We must learn from this experience and apply health-
protective requirements for all facilities that pose potential exposure to neighboring
communities, As such, we ask that you clarify in the final rule whether offsite storage
warehouses are covered facilities, and ask that the agency explore all regulatory options for
addressing emissions from these facilities.

Communities have been exposed to unmonitored and largely uncontrolled EtO pollution from
sterilization facilities for far too long. EPA’s proposed rule, which is slated to become final in
March 2024, should come as no surprise to industry stakeholders. EPA’s proposed 18 month
compliance timeline beginning in March 2024 provides more than enough time for sterilizers to
purchase and install the equipment needed to monitor and control EtO emissions pursuant to the
rule. Given the dangerous risk EtO exposure continues to present to communities, we urge EPA
to consider adopting a shorter compliance timeline in the final rule.

Thank you again for proposing a rule tightening emissions standards for EtO sterilization
facilities. We believe this rule will make significant progress in making public health the
touchstone for EtO sterilization facility regulations and reducing dangerous EtO emissions. We
also applaud the EPA’s efforts to engage and work with other agencies to fully address the public
health implications of EtO emissions. We thank you for considering our comments in our joint
effort to reassure communities that the air they breathe is safe. We look forward to working
together throughout this process as the rule is finalized and implemented.

Sincerely,
Bradley Scott Schneider Richard J. Durbin
Member of Congress United States Senator

Thomas R. CarpeN TammyDuckworth
United States Senator United States Senator
Mint Cone

Steve Cohen
Member of Congress

David Scott
Member of Congress

Henry C. "Hank" Johnson, Jr.

Member of Congress

Sean Casten
Member of Congress

Troy Carter
Member of Congress

786

Bernard Sanders
United States Senator

United States Senator

Edward J. Markey v
United States Senator

Lauren Underwood
Member of Congress

Henry Cufllar
Member @f Congress
Raphael Warnock
United States Senator

Cory A. Booker
United States Senator

Diana DeGette
Member of Congress

Robin L. Kelly e
ember of Congress

on Crow
Member of Congress

787

Chris Van Hollen
United States Senator

&éhn P. Sarbanes
Member of Congress

nSchakowsky g
ember of Congress

Nanette Diaz Barragan
Member of Congress

Emanuel Cleaver, II
Member of Congress
lember of Congress

Robert Garcia
Member of Congress

Raja Krishnamoorthi
Member of Congress

Member of Congress

Member of Congress

788

Sehifer L. McClellan
Member of Congress

Mike Quigley
Member of Congress

Alexandria Ocasio-Cortez
Member of Congress

Earl Blumenauer
Member of Congress

Suganne Bonamici
Member of Congress
Colin Z. Aftred
Member of Congress

Sheila Jackson Lee
Member of Congress

789

Ratil M. Grijalva ~
Member of Congress

Summer Lee
Member of Congress

Al Green
Member of Congress
790

Environmental Protection Agency
EPA Docket Center (EPA/DC)

Mail Code 28221T

1200 Pennsylvania Ave. NW
Washington, DC 20460

Subject: Comments for National Emission Standards for Hazardous Air Pollutants (NESHAP):
Ethylene Oxide Emissions Standards for Sterilization Facilities Residual Risk and Technology Review

Docket 1D No. EPA-HQ-OAR-2019-0178

Submitted: June 27, 2023

Dear EPA Staff,

The undersigned legislative members of the Texas House and Senate are concerned about the
communities in our state affected by Ethylene Oxide (EtO) sterilization facilities. We welcome the
opportunity to comment on the proposed EPA rule to curb the hazardous emissions these sterilization
plants pose to our Texas workers and neighboring families.

We understand the proposed rule is estimated to cut both fugitive and stack emissions of EtO from
these plants by as much as 80 percent when the rule is implemented. Though we appreciate this
projected goal, we would like the following measures included in the rule to help ensure the end results
of this action meet its intended outcome:

1. Require Fenceline Monitoring: Fenceline monitoring is a reliable and useful tool to understand
the amount of fugitive, controlled and uncontrolled emissions coming from commercial
sterilizers. Both the workers within the plants and the communities surrounding the facilities
need to be assured that they are protected. Fenceline monitoring is a proven method, as
evidenced in other facilities, for verifying the effectiveness of emission control equipment in
detecting fugitive emissions.

2. Inclusion of Off-site Storage Warehouses: The proposed rule covers EtO emissions from
commercial sterilizers and their on-site warehouses and other on-site storage areas. The
proposed rule, however, does not cover off-site warehouses and/or storage areas. We are
concerned that off-site warehouses, not included in the rule, could be used as a secondary
aeration area for off-gassing sterilized equipment, skirting the health-protective emission
controls and monitoring that is to be required at the primary facilities. High levels of fugitive
emissions have been discovered in off-site warehouses in other parts of the country. Many, if
not all, off-site warehouses are not regulated by the Clean Air Act and do not contain the
emissions controls systems necessary to capture residual EtO that is off-gassed from newly
sterilized equipment. Evidence suggests that off-site storage warehouses can generate
significant hazardous EtO emissions. For example, in 2019, the Georgia Environment Protection
Division issued a notice of violation to Beckon, Dickinson and Company, a medical sterilization
company, for operating an off-site warehouse in Covington without an air quality permit.*
Therefore, we request that off-site storage facilities be included in the rule.

1Statement from Georgia EPO Regarding BD Notice of Violation. (2019, December 20). Environmental Protection Division.
https://epd.georgia.gov/press-rel /2019-12-20/: georgia-epd-regarding-bd-notice-violation
791

3. Shorten the implementation and Compliance Timeline: Communities have long awaited the
development of this new EtO rule, having faced decades of hazardous and carcinogenic
pollution from these facilities. The EPA has proposed an 18-month timeline for the installation
of pollution controls once the final rule is issued. Every month these controls are not installed
poses an increased risk to plant workers and surrounding communities. We would like to
propose an expedited timeline of no more than 6 months for implementation to protect the
public’s health and safety.

4, EPA must continue to require that all EtO commercial sterilizers be covered in the final rule:
We are grateful that EPA requires both major and area source commercial sterilizers to comply
with the requirements of the proposed rule. it is especially important for states like Texas, since
the Texas Commission on Environmental Quality’s (TCEQ) cancer risk estimate for EtO is far
below EPA’s. We urge EPA to keep this requirement in the final rule in order to protect the
health and safety of communities like ours.

Finally, since many of these facilities are located in underserved communities of color where English
is not spoken as a first language, we would request that multilingual information on the facilities and
surrounding risks to neighboring communities be made available.

We thank the EPA for considering our-comments on this important rule to tighten the emissions
standards for EtO sterilization facilities. We look forward to seeing the finalization of this rule and
its implementation to protect the families and communities of Texas.

Sincerely,
Texas State Senators:
Senator Carol Alvarado, District 6 Senator José Menéndez, District 26

Senator Sarah Eckhardt, District 14 Senator Judith Zaffirini, District 21

Senator Roland Gutierrez, District 19 Senator Nathan Johnson, District 16
Texas State Representatives:

792

Representative Salman Bhojani, District 92

Representative John Bryant, District 114

Representative Neave Criado, District 107

Representative Mihaela Plesa, District 70

Representative John Bucy lil, District 136

Representative Ana-Maria Ramos, District 102

Representative Yvonne Davis, District 111

Representative Richard Raymond, District 42

Representative Jessica Gonzalez, District 104

Representative Ron Reynolds, District 27

fou Foe

Representative Vikki Goodwin, District 47

Representative Toni Rose, District 110

—

Representative Julie Johnson, District 115

Representative Chris Turner, District 101

Representative Venton Jones, District 100

Representative Gene Wu, District 137

Representative Terry Meza, District 105

Representative Erin Zwiener, District 45
793

Additional Texas State Representatives:

Representative Rafael Anchia, District 103 Representative Jarvis Johnson, District 139
794

American Exploration & SSENTIAL

Ming . Mining Association AINE Ls
EST. 1895 kd

Association . SSQCIATION

February 14, 2024

The Honorable Roger Williams The Honorable Nydia Velazquez

Chairman Ranking Member.

Committee on Small Business Committee Small Business ©
U.S. House of Representatives U.S. House of Representatives
Washington, D.C. 20515 Washington, D.C. 20515

Dear Chairman Williams and Ranking Member Velazquez:

On behalf of the National Mining Association (NMA), the American Exploration and Mining
Association (AEMA), and the Essential Minerals Association (EMA), we commend your
leadership in. examining the impact of the U.S. Environmental Protection Agency’s (EPA)
burdensome regulations on small businesses and the communities they support.

Our associations represent small and large businesses across the entire U.S. mining industry ~
from exploration and active mining to mine closure and reclamation. Our combined
approximately 2,500 members explore for and mine the raw materials needed for nearly every
industry and consumer product. The coal, metals, and nonmetal minerals our members produce
form the building blocks of our nation’s agriculture, energy, infrastructure, manufacturing,
defense, high-tech, and medical supply chains. The mining industry also plays a critical role in
supporting this Administration's ambitious national priorities’ and investing in local communities.

As you examine the impact of EPA's burdensome regulations on small businesses in today’s
hearing, we urge your consideration of the following:

1.) Recognize the importance of small mining companies and the businesses they
support in the communities in which they operate.

The mining industry supports nearly 500,000 direct jobs and more than 800,000 indirect jobs
nationwide.” The financial contributions of the mining industry are also significant. According to
a recent U.S. Geological Survey report, domestically mined mineral raw materials contribute

1 The White House, Fact Sheet: Sécuring a Made in America Supply Chain for Critical Minerals (Feb. 22,

2022), available at https.//www.whitehouse.gov/briefing-roonv/statements-releases/2022/O2/22/fact-sheet-
securing-a-made-in-america-supply-chain-for-critical-minerals/ (last visited Jan. 31, 2024). (“Critical
minerals provide the building blocks for many modern technologies and are essential to our national

security and economic prosperity.”

2 National Mining Association, 2023 Mining Facts, at 4, avaifable at https://nma.orq/wp-
795

$105 billion to the U.S. economy. Additionally, the value added to the U.S. gross domestic
product by major industries that consume processed mineral materials is $3,840 billion.?

Because many mine projects are located in rural, economically disadvantaged areas with limited
job opportunities and public services, a mining operation can become a community's, and even
a region's, best and often only opportunity to improve the quality of life for everyone. Many
mining companies make substantial financial investments in their local communities to build or
improve schools, upgrade roads, utility, and internet services, subsidize medical services, offer
vocational training to prospective employees, and provide scholarships and other educational
opportunities for their workforces. These investments represent positive contributions to the
communities in which they operate, in addition to the state and local taxes the mines pay, which
create positive returns not only for the company but for the entire region.

Many of our members are also classified as small businesses. These small mining companies
create jobs and economic opportunity in communities that often need these investments most.
Unfortunately, EPA’s crushing regulatory agenda has made it more difficult and expensive for
these small businesses to operate. This has created a ripple effect, harming not just our small
business miners, but also the small indirect industries that rely on the mining industry.

2.) Champion clear, predictable, and reasonable regulations.

The U.S. mining industry is one of the most regulated industries on the planet. Comprehensive
environmental and health and safety regulations, at the federal, state, and local levels, govern
nearly every inch of a mining operation. We strongly support reasonable regulations that protect
the environment and health and safety while also ensuring tat domestic natural resource
development is viable and globally competitive. Clear, predictable, and reasonable regulations
provide certainty and clarity that are crucial for mining operations. This is especially important
considering the significant time, investment, and effort required to successfully permit and
construct a mining or processing operation. All of this requires a vast investment that miners
must pay over a period of years or even decades before seeing any revenue in return once
operations begin. Mining entities must have long term clarity and certainty that regulations will
not make their operation impossible or nonviable before making those investments to produce
vital mineral resources domestically.

3.) Provide oversight of EPA’s required economic impact analysis on small
businesses and compliance with the Regulatory Flexibility Act (RFA), the Small
Business Regulatory Enforcement Fairness Act (SBREFA), and the Administrative
Procedure Act (APA).

Finally, we urge the Committee to exercise its oversight authority to ensure EPA conducts
required economic impact analyses and complies with the statutes requiring the consideration of
impacts on small businesses. Under this administration, EPA has either glossed over or ignored
altogether the economic impact analysis on small businesses and the subsequent notice and
comment process that is required under the RFA, SBREFA, and the APA. Quite often in a
proposed rule, the agency will include a cursory acknowledgement that the rule will not have a
substantial impact on a significant number of small businesses but fail to undertake a serious,
thorough review of the impact on small businesses.

One such example was the June 28, 2021, proposed rule on reporting and recordkeeping
requirements for per-and polyfluoroalkyl substances (PFAS) under the Toxic Substances

3U.S. Department of the Interior, U.S. Geological Survey, Mineral Commodity Summaries 2024 at 4,
available at https://pubs.usgs.gov/periodicals/mcs2024/mes2024 pdf (last visited Feb. 14, 2024).
796

Control Act (TSCA). When EPA initially certified that the proposed rule would not have a
significant impact on a substantial number of small businesses, the Small Business
Administration’s Office of Advocacy (SBA-OA) called EPA to task. As a result of evidence
provided by (SBA-OA), EPA was forced to amend the estimated costs from the proposed rule
from $10.8 million to $875 million.* SBA contends that even the updated figures were still
inadequate, and EPA should have started over by re-proposing the rule.

Following this episode, EPA has taken more steps to adhere to SBREFA, but these efforts could
only be described as symbolic. SBA-OA has repeatedly criticized EPA for underestimating the
impact of proposed rules, cutting corners or disregarding feedback from small businesses. To
note one example among many: In the August 9, 2023, EPA proposed rule “Revisions to Air
Emissions Reporting Requirements,” SBA's Office of Advocacy again called out EPA for cutting
procedural corners that will ultimately cost small businesses dearly. While the agency did seek
greater input from smail businesses on the impact of greater emissions reporting, the agency
subsequently ignored this input, resulting in a proposed rule that does not provide small
businesses with the necessary tools to comply. Penalties for noncompliance under the Clean Air
Act can be severe. As a result, smail businesses are left to figure out for themselves whether
they must comply with the rule, how to do so, and then shoulder the increased costs.°

We encourage the Committee to exercise its oversight duties and make sure the RFA, SBREFA
and the APA are being faithfully observed, Sadly, EPA is not alone among agencies giving short
shrift to these laws. The federal government should not overlook the impact on small
businesses to push new rules out the door as quickly as possible.

We appreciate the Committee's support of the small businesses that will create jobs, strengthen
our communities, and provide the energy and materials that are the foundation of our economy.
We look forward to continuing to work with you. ,

Sincerely,

National Mining Association
American Exploration and Mining Association
Essential Minerals Association

4 Comments of the U.S. Small Business Administration Office of Advocacy, TSCA Section 8(a)(7)
Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances; Notice of
Data Availability and Request for Comment; Docket ID No. EPA-HQ-OPPT-2020-0549; at 3, available at
Reporting-IRFA-12.19.22-508c.pdf (last visited Feb. 14, 2024).

5 Comments of the U.S. Small Business Administration Office of Advocacy, Revisions to the Air
Emissions Reporting Requirements, 88 Fed. Reg. 54,118 (August 9, 2023), Docket ID. EPA-HQ-OAR-
2004-04889, at 4, available at https://advocacy.sba.gov/wp-content/uploads/2023/11/Comment-Letter-
Revisions-to-the-AERR-508. pdf (last visited Feb. 14, 2024). (“The requirement that smail entities comply
regardless of the availability of the necessary emissions estimation tools is extremely
problematic...Unless EPA provides greater accommodations to small entities in the absence of the
promised tools, the impacts on small entities would be severe.”)
797

NGVAMERICA

Matthew Brownlee

Hitura! Gas Vahicies for Americs Director, Federal Government

“esl seca REE Affairs

202.824.7363 office/fax

ngvamerica.arg

Hon, Roger Williams . Hon, Nydia Velazquez

Chairman Ranking Member
House Committee on Small Business House Committee on Small Business
Rayburn House Office Building Rayburn House Office Building

Chairman Williams and Ranking Member Velasquez,

NGVAmerica respectfully submits this statement for the record in response to the Committee’s
February 15, 2024 hearing titled “Burdensome Regulations: Examining the Impact of EPA
Regulations on Main Street.” Our interest in this hearing concerns the U.S. ERA proposed Phase 3
Heavy Duty Greenhouse Gas Regulations.1 We appreciate the Committee’s interest in reviewing the
impact that these and other regulations will have on small businesses.

NGVAmerica submitted extensive comments on EPA's Phase 3 notice. Our comments addressed
ways in which the EPA can amend its proposal and regulations to account for the benefits of natural
gas trucks that operate on renewable natural gas, a low-carbon and sometimes carbon-negative
transportation fuel. The majority of motor fuel used by natural gas vehicles is renewable natural
gas and this fuel if given credit under EPA’s vehicle regulations would provide a lower-cost and
better performing solution for many businesses operating trucks to transport goods. If this
solution were incorporated into EPA’s rules it would lower the cost of compliance and enable fleets.”
that already have invested in natural vehicles and fueling to continue to benefit from those
investments, It also would benefit small businesses that purchase used vehicles on the secondary
market, because natural gas vehicles provide a 1:1 substitution for diesel vehicles and benefit from
a widely available, truck-friendly fueling network.

As currently written, the EPA’s regulations do not account for upstream emissions, not from
batteries, vehicle production, fuel production or vehicle production. The EPA previously indicated
that it intended to require an assessment of upstream emissions associated with electric vehicles as
part of its vehicle regulations but has more recently indicated that it does not plan to pursue such
treatment. While we have no position on the necessity of accounting for upstream emissions from
batteries or electric vehicles, we do take issue with not providing credits for lower-carbon fuels.
The reality is that not providing credits for the emission benefits of lower carbon fuels is the same
as penalizing the vehicles that operate on lower-carbon fuels because these vehicles will have to

‘Docket ID No. EPA-HQ-OAR~ 2022-0985, Greenhouse Gas Emissions Standards for Heavy Duty Vehicles—
Phase 3; 88 FR 25926 (April 27, 2023).

use of NGVs where they benefit most. |
‘onment. For health. For security. For America.
798

acquire offsets or emission credits from other vehicles to satisfy future, more demanding tailpipe
standards.

Eventually the only way a manufacture would be able to continue to offer natural gas vehicles or
other internal combustion engines is to acquire emission offsets from electric or fuel cell vehicles,
since the regulations ignore the emission benefits of operating vehicles on lower carbon fuels.
While it may be feasible to purchase emission credits this will increase costs and require that
natural gas subsidize the cost of other more costly technologies such as battery electric vehicles and
fuel cell trucks.

The issues described here are explained in greater detail in our comments where we ask EPA to
expressly provide a carbon correction factor for renewable natural vehicles. This carbon correction
factor would adjust the regtilated emissions based on the average carbon intensity of fuel
consumed while also factoring for the amount of lower carbon fueled consumed relative to
conventional natural gas consumed.

We welcome the opportunity to.discuss this matter more with the committee. A copy of our

comments is available in the EPA docket here: https://www.regulations.gov/comment/EPA-HQ->
QAR-2022-0985-1522.

Sincerely,

Matthew Brownlee
Director, Federal Government Affairs

of NGVs where they benefit most.
vironment. For health, Far security. Far America,

Advocating the increasing
Far the economy. For the
799

U.S. Chamber of Commerce

1815 H Street, NW
Washington, DC 20062-2000

February 14, 2024
The Honorable Roger Williams The Honorable Nydia Velazquez
Chairman Ranking Member
Committee on Small Business Committee on Small Business
U.S. House of Representatives U.S. House of Representatives
Washington, DC 20515 Washington, DC 20515

Re: Statement for the Record for the Hearing, “Burdensome Regulations: Examining the
Impact of EPA Regulations on Main Street”

Dear Chairman Williams and Ranking Member Velazquez:

Thank you for holding the hearing today on how burdensome regulations impact Main
Street. My name is Natalie Kaddas and | am the CEO of Kaddas Enterprises in Salt Lake City,
Utah. | also serve as the Chair of the Small Business Council at the U.S. Chamber of Commerce.
Currently, 96% of Chamber member companies have fewer than 100 employees and 75% have
fewer than 10, The Small Business Council works to ensure the views of small businesses are
integrated into the Chamber’s policy-making process.

My manufacturing company in Salt Lake City specializes in manufacturing thermoform
plastic products for the energy, transportation and aerospace industries. Our largest source of
revenue is our patented designs of BirdguarD™ products, designed to protect birds and other
animals from electrocution. Our products also aid greatly in energy resilience by preventing
wildlife-caused power outages.

There are roughly 33.1 million small businesses in the U.S. that comprise over 99% of all
U.S. businesses, represent 43.5% of America’s GDP, and account for 62% of net job creation
since 1995. The power of innovation and entrepreneurship has spurred remarkable growth
since the COVID-19 pandemic in the face of high inflation, worker shortages, and high interest
rates. Unfortunately, the crushing burden of federal regulation threatens this small business
growth.

The most recent estimate pegs compliance with federal regulations at more than $3
trillion per year. According to the National Association of Manufacturers (“NAM”), that cost
exceeds the entire annual economic output of the manufacturing sector. That NAM study
estimates a burden of $28,000 per employee per year for manufacturers of our size, which is
more than double of all other companies, of similar size, in other industries.
800

Forty-four years ago, the Regulatory Flexibility Act (“RFA”) was enacted seeking to
correct the disproportionate burden by encouraging federal agencies to transparently consider
the impact of new regulations on small businesses and to minimize negative impacts without
compromising the underlying regulatory objectives. When President Carter signed the RFA into
law, he stated that-“small businesses are vital to the growth and to the future of our country”
and that regulations “can impose a disproportionate and unfair burden on smail businesses.”

Even though the Office of Advocacy at the U.S. Small Business Administration (“SBA”),
the independent office responsible for overseeing regulators’ compliance with the RFA, is trying
to convince federal regulators to comply with the RFA, the Office’s efforts at times seem futile.
The National Federation of Independent Business (“NFIB”) reviewed comment letters from the
Office of Advocacy from January 1, 2021 — January 1, 2023, and found 28 instances where the
Office of Advocacy cited agencies for lack of RFA compliance. Those public letters unveiled
loopholes in the law that regulators use as excuses to bypass and misrepresent the costs of
regulatory proposals because (a) there is no way to go to court to challenge even the most
absurd “certifications” that a proposal will not harm small businesses and (b) agencies only
publish what they characterize as the direct impact on regulated firms, disguising the actual
harm to small businesses. —

One of the most egregious failures to consider smail business and issue inadequate
“certifications” required by the RFA has arisen in the series of Waters of the United States
(“WOTUS”) rulemakings promulgated by the U.S. Environmental Protection Agency (“EPA”) and
the U.S. Army Corps of Engineers (“Corps”). Rather than seek appropriate input from small
businesses on how to manage wetlands permitting in a way that would be both
environmentally protective and sensitive to impacts on small businesses, EPA and the Corps
“certified” under the RFA in 2014 — that their proposed WOTUS rule would not have a
“significant economic impact on a substantial number of small entities.” Now, ten years later,
after the U.S. Supreme Court has sharply rejected the agencies’ claims of authority to impose
wetlands permitting requirements, the agencies have yet to formally consider small business
views, as required by the RFA, on how wetlands can be defined without unduly burdening small
businesses.

Agency exploitation of interpretations of the RFA loophole that limit it to requiring
consideration of small business impacts for directly regulated businesses is apparent in the
ongoing Basel III Endgame rulemaking. Bank regulators published their perceived economic
impact on large banks but were not transparent about how new mandates will make small
business loans more expensive.

Legislation is pending that will close those real or apparent loopholes and allow for
meaningful smail business input in the federal regulatory process. The urgency for Congress to
act was described before this Committee several weeks ago when former CBO Director Douglas
Holtz-Eakin explained that costs from regulatory mandates issued under the Biden
Administration are 50% greater than under any previous administration.
801

H.R, 7198, the Prove It Act, sponsored by Representative Finstad, Representative
Moran, and Representative Caravaro, strengthen the RFA to avoid agency evasions by allowing
small businesses to directly challenge an agency's “certification” and by requiring agencies to
be fully transparent about how regulations will impact the small business community.

The U.S. Chamber of Commerce, along with 47 national trade and membership ©
organizations representing small business owners, along with over 100 local and state
chambers of commerce ask that members of this Committee update the RFA and close real or
apparent loopholes that shut-out small business input. Furthermore, we respectfully ask
members of this Committee to sign on as co-sponsors to H.R. 7198 and that the Committee

Minimizing red tape will enable small businesses to do what they do best - drive
innovation, bolster communities, and create jobs.

Please do not hesitate to contact Tom Sullivan, the Chamber’s Vice President for Small
Business Policy, if you have questions or comments regarding the content of this statement for
the record.

Sincerely,
Natalie Kaddas
CEO, Kaddas Enterprises, Inc.

Chair, Small Business Council
U.S. Chamber of Commerce

Attachment: February 1, 2024 Letter on Small Business Input in Federal Rulemaking
cc: Members of the House Committee on Small Business
802

February 1, 2024
The Honorable Roger Williams The Honorable Jim Jordan
Chairman Ranking Member
Committee on Small Business Committee on the Judiciary
U.S. House of Representatives U.S. House of Representatives
Washington, DC 20515 Washington, DC 20515
The Honorable Nydia Velazquez The Honorable Jerrold Nadler
Ranking Member Ranking Member
Committee on Small Business Committee on the Judiciary
U.S. House of Representatives U.S. House of Representatives
Washington, DC 20515 Washington, DC 20515

Re: Small Business Input in Federal Rulemaking
Dear Chairmen Williams and Jordan and Ranking Members Velazquez and Nadler:

On behalf of millions of small businesses across the country, we urge legislative action to
strengthen the meaningful input of small businesses in federal regulatory processes and ensure
the intent of the Regulatory Flexibility Act is fulfilled.

The Regulatory Flexibility Act (RFA) of 1980 was signed into law after a bipartisan coalition of
small businesses, community leaders, and elected representatives confronted the danger of
imposing burdensome red tape on American small businesses. Upon signing the RFA into law,
President Carter stated that “small businesses are vital to the growth and to the future of our
country” and that regulations “can impose a disproportionate and unfair burden on small
businesses.”

The RFA sought to correct this disproportionate burden on small businesses by encouraging
federal regulatory agencies to transparently consider the impact of new mandates on small
businesses and to minimize negative impacts without compromising the underlying regulatory
objectives,

Unfortunately, loopholes in the RFA allow federal regulators to bypass the law’s requirements
and misrepresent the costs of new mandates on small businesses because (a) transparency
requirements only apply to businesses directly regulated and (b) judges may not punish agencies
for ignoring small business concerns.

Federal agencies have on numerous occasions failed to comply with requirements under the
RFA. In 2023, the National Federation of Independent Business (NFIB) reviewed comment
letters from the Office of Advocacy at the U.S. Small Business Administration (SBA), the
independent office responsible for overseeing compliance with the RFA, from the 117" Congress
and found 28 instances where SBA’s Office of Advocacy cited agencies for lack of RFA
compliance. SBA’s Office of Advocacy found agencies often improperly certify that rules will
not have a significant economic impact on a substantial number of small entities, only consider
803

the direct costs on small businesses, or misrepresent the costs on small businesses from
regulation.

For example, SBA’s Office of Advocacy found the Department of Labor’s analysis of the impact
of its independent contractor rule “deficient” because it "severely underestimate[d]” the
economic impacts of the rule on small business; and “failed to estimate any costs” for small
businesses to reclassify independent contractors as employees.

Agency exploitation of the loophole that only requires publishing small business impacts for
directly regulated businesses is apparent in the ongoing Basel III Endgame rulemaking. Bank
regulators published their perceived impact on large banks but did not publish how new
mandates will make small business loans more expensive.

The Environmental Protection Agency/Army Corps of Engineers Waters of the United States
(WOTUS) final rule is a case study in agency misrepresentation of a regulation’s costs on small
businesses, In their rule, the agencies certified the rule “will not have a significant economic
impact on a substantial number of small entities.” For decades, bipartisan administrations have
claimed that revising the WOTUS definition will not harm small businesses. Yet the millions of
farmers, homebuilders, and other industries heavily dominated by small businesses render such a
“certification” implausible. Moreover, they highlight a major problem — small businesses lack
the legal recourse to force regulators to take them seriously and judges’ hands are tied when it
comes to holding agencies accountable to small business concerns.

Unfortunately, the concerns raised in this letter are not new. In fact, SBA’s Office of Advocacy
has sought to close the loopholes over the past 40 years but has not been successful.

Our concern that small businesses are being shut out of the regulatory process are amplified by
recent data showing the growth of federal red tape. The National Association of Manufacturers’
most recent study on the cost of regulation shows that the cost per employee to comply with
federal regulations is three times greater for small firms than the average costs for manufacturers.
Former CBO Director, Douglas Holtz-Eakin recently testified before the Small Business
Committee that the costs from regulatory mandates currently being issued are fifty percent
greater than under any previous administration.

At a time when we are counting on small business growth to enrich communities and bolster
America’s economy, we cannot afford to bury free enterprise under red tape emanating from
Washington.

We urge the Committee to prioritize legislation that strengthens and closes loopholes in the
Regulatory Flexibility Act.

We thank you for your leadership to create an environment where small businesses can operate,
invest and grow. We look forward to working with you on ways to reduce red tape and burdens
for small businesses.

Sincerely,
National

Alliance for Chemical Distribution

American Bakers Association

American Bankers Association

American Chemistry Council

American Farm Bureau Federation

American Foundry Society

American Hotel and Lodging Association

American Land Title Association

American Road & Transportation Builders
Association

Associated Builders and Contractors

Associated Equipment Distributors

Associated General Contractors of America

Associated Wire Rope Fabricators

Brick Industry Association

Consumer Bankers Association

Consumer Brands Association

Council for Responsible Nutrition

FMI - The Food Industry Association

Independent Electrical Contractors

Independent Lubricant Manufacturers
Association

Independent Petroleum Association of
America

Innovative Lending Platform Association

International Franchise Association

International Sign Association

Job Creators Network

Leading Builders of America

Metals Service Center Institute

National Association for Surface Finishing

National Association of Home Builders

National Association of Insurance and

Financial Advisors

National Association of Wholesaler-
Distributors

National Automobile Dealers Association

National Federation of Independent
Business (NFIB)

National Funeral Directors Association

National Mining Association

National Parking Association

National Retail Federation

National Roofing Contractors Association

National Rural Electric Cooperative
Association

National Small Business Association
(NSBA)

National Stone Sand & Gravel Association

National U.S. India Chamber of Commerce
Small Business & Entrepreneurship Council
Small Business Investor Alliance

The Toy Association

Treated Wood Council

U.S. Chamber of Commerce

Alabama

Albertville Chamber of Commerce
Central Baldwin Chamber of Commerce

Arizona

Chandler Chamber of Commerce

Greater Flagstaff Chamber of Commerce

Greater Phoenix Chamber

Lake Havasu Area Chamber of Commerce

Nogales Santa Cruz County Chamber of
Commerce

Northwest Valley Chamber of Commerce

Tucson Metro Chamber

Arkansas
Holiday Island Chamber of Commerce
California

Buellton Chamber of Commerce

Carlsbad Chamber of Commerce

Coalition of California Chambers - Orange
County

Fremont Chamber of Commerce

La Verne Chamber of Commerce

Long Beach Area Chamber of Commerce

Los Angeles Area Chamber of Commerce

Palos Verdes Peninsula Chamber of
Commerce

Rancho Cordova Area Chamber of
‘Commerce

San Juan Capistrano Chamber of Commerce

Western States Trucking Association

Yorba Linda Chamber of Commerce

Colorado

Alamosa County Chamber of Commerce
Denver Metro Chamber of Commerce
Greater Woodland Park Chamber

Vail Valley Partnership
Florida

Coral Gables Chamber of Commerce
Lakeland Chamber of Commerce

Georgia

Habersham County Chamber of
Commerce

Murray County Chamber of Commerce

Guam

Guam Chamber of Commerce

Idaho

Boise Metro Chamber of Commerce

Jerome Chamber of Commerce

Pocatello-Chubbuck Chamber of
Commerce, Inc.

Dixon Chamber of Commerce & Main
Street

Edwardsville/Glen Carbon Chamber of
Commerce

GLMV Chamber of Commerce

Greater Rockford Chamber of Commerce

Joliet Region Chamber of Commerce &
Industry

Sauk Valley Area Chamber of Commerce

The Greater Springfield Chamber of
Commerce

‘West Suburban Chamber of Commerce &
Industry

Indiana

Crossroads Chamber Indiana
Indiana Chamber of Commerce
South Bend Regional Chamber

Iowa

Quad Cities Chamber of Commerce

Kansas

Grant County Chamber of Commerce
Greater Topeka Chamber

Louisiana

Greenwood Chamber of Commerce
Maryland

Talbot County Chamber of Commerce
Massachusetts

Metro South Chamber of Commerce
Michigan

Battle Creek Area Chamber of Commerce
Detroit Regional Chamber

Hartland Area Chamber of Commerce
Jackson County Chamber of Commerce
Oscoda-AuSable Chamber of Commerce

Minnesota

Greater Mankato Growth
Minnesota Chamber of Commerce

Mississippi

Hancock County Chamber of Commerce
Missouri

Greater Kansas City Chamber of Commerce
Montana

Billings Chamber of Commerce

Montana Chamber of Commerce

Nevada

Vegas Chamber

New Jersey

New Jersey State Chamber of Commerce
‘4
New York

Capital Region Chamber
North Country Chamber of Commerce
Sullivan County Chamber of Commerce

North Carolina

The Caldwell Chamber

North Dakota

Greater North Dakota Chamber

Broken Arrow Chamber of Commerce
Edmond Area Chamber of Commerce

Oregon

Canby Area Chamber of Commerce
Gresham Area Chamber of Commerce
Lincoln City Chamber of Commerce
Oregon Business & Industry

Roseburg Area Chamber of Commerce

Pennsylvania

Blair County Chamber of Commerce

Columbia Montour Chamber of Commerce

Hanover Area Chamber of Commerce

Harrisburg Regional Chamber

Huntingdon County Chamber of Commerce

Lancaster Chamber of Commerce

Pennsylvania Chamber of Business and
Industry

Pittsburgh Airport Area Chamber of
Commerce

cc: Members of the Committee on Small Business
Members of the Committee on the Judiciary

Schuylkill Chamber of Commerce
South Carolina

Greater Columbia Chamber of Commerce
Texas

Alvin-Manvel Area Chamber of Commerce
Coppell Chamber of Commerce
Irving Hispanic Chamber of Commerce

Utah

ChamberWest Chamber of Commerce
Salt Lake Chamber
St. George Area Chamber of Commerce

Virginia

Central Fairfax Chamber of Commerce
Loudoun County Chamber of Commerce

Washington

Burlington Chamber of Commerce

Greater Lake Stevens Chamber of
Commerce

Mercer Island Chamber of Commerce

Pullman Chamber of Commerce & Visitor
Center

Shelton-Mason County Chamber of
Commerce

Wyoming

Casper Area Chamber of Commerce
Greater Cheyenne Chamber of Commerce
Riverton Chamber and Visitors Center
Rock Springs Chamber of Commerce
Wyoming State Chamber of Commerce


File and source

File

CHRG-118hhrg54743.pdf

Size

52,494,735 bytes

SHA-256

41337317e80e38516a2861161e6f8a6464b88a73deb7edea607af66428bcd8b2

Our copy

CHRG-118hhrg54743.pdf

Original

www.govinfo.gov