Comments from Associated Owners and Developers Submitted to EPA Regarding the Advanced Notice of Proposed Rulemaking for Greenhouse Gases Under the Clean Air Act

Associated Owners & Developers ("AOD") is pleased to submit these comments in response to the Advance Notice of Proposed Rulemaking ("ANPR") on Regulating Greenhouse Gases Under the Clean Air Act ("CAA" or "Act") issued by the Environmental Protection Agency ("EPA") and published in the Federal Register on July 30, 2008.

AOD supports the overall effort to address climate change and agrees that we all need to do our part to reduce greenhouse gas emissions globally. However, the CAA as currently structured is not the right vehicle for achieving those goals. Regulating greenhouse gas emissions from any source under the Act, as EPA acknowledges, will subject our industry to a construction permitting
program that the Act and regulations were not designed to encompass. Subjecting more than a million new sources to an administratively complex and costly permitting process would not materially reduce the nation's greenhouse gases and would create substantial regulatory uncertainty and unnecessary regulatory barriers at a time when this industry can least afford it.