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Government
& Public Affairs Update
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Government &
Public Affairs Team
Reginald M. Turner
John
Van Fossen, Practice Group Leader
Lucius A. Vassar
Chris Wagner
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Levin Urges Provisions That Seek to
Keep Manufacturers & Auto Industry Competitive
The Office of
Senator Carl Levin (D-MI) today made public his March 5 letter to
climate change advocate Senator John Kerry (D-MA), who is busy
drafting the Senate's bill. The text of Levin's letter is
below:
March 5, 2010
The Honorable
John Kerry
Chairman
Committee on Foreign Relations
United States Senate
Washington, D.C. 20510
Dear John:
I am writing to reiterate some of the points I made at the March 2
meeting on climate legislation:
- A binding national standard for
greenhouse gas emissions from mobile sources is needed, with
clear pre-emption of states adopting a different standard.
The rules for greenhouse gas emissions from stationary sources
should be set by Congress, superseding EPA's existing statutory
authority under the Clean Air Act.
- A realistic and firm "price
collar" is needed to ensure that businesses and consumers
do not face excessive costs and to provide more certainty for
businesses to invest in the new clean energy economy.
- A delay of at least 10 years in
regulation of industrial sources is needed, with a further delay
provided for if important trade provisions to assure a level
playing field are not included and fully implemented.
Sufficient allowances for industrial sources are needed to cover
both direct and indirect emissions. This is critical for
ensuring that cost disparities relative to greenhouse gas
controls do not erode our international competitiveness.
- Any approach for reducing greenhouse
gas emissions needs to take into account the differences in the
source of electricity generation across the country, in order to
avoid regional disparities. An allocation formula based 50
percent on emissions and 50 percent on sales would result in
some states bearing an unfair and disproportionate share of the
costs. As can be seen in the attached table, a 50-50
allocation would result in a wide disparity in the extent to
which emission allowance needs are met, with a difference across
states of 47%. A 100% emissions-based distribution formula
is a more equitable approach (but there still is a difference
across states of 22%). An adequate total number of
allowances to the electricity sector is also needed to ensure a
realistic and smooth transition to lower carbon-intensive
electricity production.
Thanks.
Sincerely,
Carl Levin
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If you have
any questions concerning these issues, please contact Chris Wagner at
202.772.0924 or cwagner@clarkhill.com.
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To find out
more about Clark Hill and our Government & Public Affairs
Practice Group, visit clarkhill.com
or call 800.949.3124
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