Comments from Governor Rick Perry Submitted to EPA Regarding the Advanced Notice of Proposed Rulemaking for Greenhouse Gases Under the Clean Air Act

Please accept these comments in response to the Advance Notice of Proposed Rulemaking (ANPR) on Regulating Greenhouse Gases under the Clean Air Act (CAA) issued by your agency on July 30, 2008. In order to assess the impact of the regulations contemplated in the ANPR, I created an advisory panel of Texas' energy and environmental agency leaders to prepare an analysis of your proposal. Their report is enclosed, and highlights Texas' serious concerns about this proposed unprecedented expansion of EPA regulation over virtually every sector of the economy, the massive costs that will be imposed on our economy, and the certainty that the proposed regulations will fail to achieve the intended goals of tangible reductions in greenhouse gas concentrations given the global nature of these emissions.

Texas is the nation's leading energy progucer, supplying 20 percent of the nation's oil production, one-third of the nation's natural gas production, a quarter of the nation's refining capacity and nearly 60 percent of the nation's chemical manufacturing. We are also developing the cutting edge of new energy technologies. Texas has pioneered production technology that has opened the nation's vast shale formations for production and resulted in record growth in the nation's natural gas reserves.