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from the public should be included in the basic statutes. We believe Section 108(aX2) 

 specifically provides those restrictions. 



We are concerned that the Bureau is directed to analyze and publish information 

 op effects on the public and the environment of those pollutants" Section 



108(aXAXu). This analysis is not a statistical function, the capability and duty lies in 

 Agency for Toxic Substances and Disease Registry (ATSDR), Centers for Disease 

 Control (CDC) and other parts of the EPA. Overlap of that responsibility with the 

 new Bureau" is not efficient or within the mission of the bureau to publish envi- 

 ronmental data. 



We are also concerned that the responsibilities proposed for the Bureau may over- 

 lap with responsibilities already assigned by law to the Department of Energy. For 

 instance, Section 1605 of the Energy Policy Act of 1992 assigns to the Secretary of 

 Energy responsibility for collection of certain statistics regarding greenhouse gas 

 emissions. The language of Section 108 should be revised to make clear that any 

 information collection or coordination responsibilities created for EPA by this act 

 are subordinate to such responsibilities already assigned by law to other agencies. 



We endorse the stipulation in Section 108 (c)(4) that the proposed Environmental 

 Statistics Annual Report include "economic information on the current and project- 

 ed costs and benefits of environmental protection." 



The principle that environmental protection actions or policies be based on rigor- 

 ous economic analysis of the expected costs and benefits is critically important. We 

 know the American people want a clean environment, so do we. At the same time, 

 we believe that the American people also highly value the many benefits of an ex- 

 panding economy. A good and rising standard of living is still a part of the Ameri- 

 can dream. So, CMA believes it is imperative that the effect of proposed environ- 

 mental protection measures on important American values — including but not limit- 

 ed to environmental protection — be fully and methodically considered. 



There is another important point. We live in an era of scarce resources. Our Fed- 

 eral Government is running an enormous deficit and accumulating debt at an 

 alarming rate, debt which threatens the well-being of our children and grandchil- 

 dren as well as ourselves. Our manufacturing industries, including the chemical in- 

 dustry, are operating in an increasingly competitive global environment where con- 

 stant attention to efficiency and costs is critical not only to continued prosperity, 

 but to survival. Under these circumstances, only the most thoroughly justified and 

 highest priority measures which impose new costs on government or industry are 

 defensible. 



Given the importance of cost analysis to environmental protection measures, 

 CMA proposes that an additional "general finding" be added to Section 102 of S. 171 

 to recognize this point. 



7\tle II — Interagency Committee on Global Environmental Change 



The International Energy Conference proposed in Sec. 201, and the International 

 Greenhouse Gas Monitoring Program proposed in Sec. 202, both seem duplicative of 

 ongoing activities a) within the Organization for Economic Cooperation and Develop- 

 ment (OECD), International Energy Agency (lEA); b) the Intergovernmental Panel 

 on Climate Change (IPCC) of UNEP and WMO; and, the Intergovernmental Negoti- 

 ating Committee and, after ratification, the Conference of the Parties of the U.N. 

 Framework Convention on Climate Change. We recommend that this Title be delet- 

 ed. 



Title III — Commission on Improving Environmental Protection 



CMA believes that Title HI is an important and potentially very promising fea- 

 ture of S. 171. Creation of a commission on Improving Environmental Protection to 

 review laws, policies and regulations to unite and rationalize environmental protec- 

 tion programs is sorely needed. 



Members of CMA and others in the regulated community are frequently con- 

 founded, frustrated and baffled by conflicting, overlapping and duplicate require- 

 ments. The result is sometimes reduced protection for the environment and in many 

 cases expenditures for no net improvement in protection. 



The commission should seek a broad array of opinions from the public and mem- 

 bers of the regulated community. We applaud the creation of advisory groups in 

 Section 305 to provide input. We request that industry be specifically included as 

 members of one or more of advisory groups created to assist the commission. 



The commission could, if well staffed and funded, produce recommendations that 

 would streamline and prioritize the Nation's environmental objectives. It could help 

 us spend resources where they are currently needed rather than in programs and 

 activities that no longer have relevance. Likewise, they could help us refocus on un- 

 finisheid business before we reach for new objectives. 



