Small businesses would bear the brunt of the effect of increased energy costs and other taxes, both direct and indirect, which would be necessary to reduce "greenhouse gas" emissions as proposed by the Administration. Already for some business owners, the costs imposed by government regulation surpass the burden of high taxes and cumbersome tax codes. And as their numbers hit historic levels, regulations and mandates have become a greater threat to the growth and survival of some firms. Such an ill-conceived treaty would only make a currently unacceptable regulatory burden much worse, and in many cases seriously throw the lives of business owners, their employees, and their families into turmoil and economic austerity. Unfortunately, our concerns regarding the economic impact on small business owners and their employees seem to have fallen on deaf ears at the White House. The Administration has elected to not even respond to a request by the Small Business Survival Committee (SBSC) under the Freedom of Information Act (FOIA) for the conclusions, data and evidence supporting its position on the proposed treaty addressing the theory of "Global Warming." SBSC filed its request May 18, and has not received any response by mail or telephone as requested -- and as required by law within 10 days - despite follow-up courtesy calls to CEA seeking comment on the status of the request. CEA REFUSAL TO COMPLY WITH FOIA CEA has now repeatedly testified before Congress that it concludes the treaty would have only a "minimal" or "modest" impact on the United States' economy. This is in direct contradiction to forecasts -- supported by publicly released assumptions, models, and data -- developed by various highly respected private economists. CEA Chair Yellen has made an offer, repeated to this Committee but unsupported by any statutory authority, that Congress may inspect certain documents relating to its analysis, but only by contacting and under the supervision of the White House Counsel's office. Unless this constitutes an as yet undeclared invocation of Executive Privilege, this bizarre method of inspection represents a unique utilization of current law, and an apparent confusion of proper constitutional roles. SBSC must ask, what is the Administration attempting or seeking to shield or avoid in this debate? The public has a right to know whether the "global warming treaty" being advanced by its government threatens American jobs and economic security. The Administration is fully aware of the above-cited economic impact, to the extent the relevant officials will let themselves believe the three studies conducted by various government agencies (of which we are aware), and which have come into the possession of opponents of the treaty. All of these show dramatic economic impacts, yet less than various studies conducted by non-interested firms at the request of impacted parties in the private sector. Far more disappointing, however, is the Administration's public stance. That is the position taken, including on several occasions now before Congress, by the Council of Economic Advisors, that there will be at most “minimal” impact on the typical American family. This is not only inconsistent with every study conducted to date for which any of the assumptions and data are available, but also is being held forth without any substantiation. In fact, not only has CEA Chair Janet Yellin testified to Congress that her testimony constituted her analysis, but CEA is now in violation of the law as this Committee's record closes (6/11/98). CEA has not only not provided a reason for not providing the information sought by SBSC in its FOIA request, it has failed to even attempt to comply with the law's requirement it respond within 10 days. Aggravating this violation of the law, numerous phone calls to Ms. Michelle Jolin, the responsible CEA official, have gone unreturned. In the alternative to providing the information -- which to date CEA has refused even Congress on what appears to be some mutated version of (undeclared) Executive Privilege -- CEA may refuse the request, providing one of several prescribed reasons for doing so. Instead, knowing there is no acceptable response, it has not provided any. The most likely claim we anticipate, upon litigating the matter, is that the analysis is not final. In such case the Administration should cease making policy positions based upon these analyses. An alternative, which is a feasible “option” only in that we understand CEA has intimated to Congress this is its rationale for not providing the information, is "national security." If, however, there is any truth whatsoever to that claim, Congress should immediately intervene and initiate an inquiry into the national security implications of releasing economic data supporting an analysis of a treaty the Administration is nonetheless apparently seeking to slip by the American public without being open and honest, and without the constitutionally mandated Senate ratification. CONCLUSION SBSC is joined by numerous concerned interests in believing this treaty will cause unfair, unnecessary and unprecedented harm to the U.S. economy, while nonparticipating nations avoid any similar commitments to address this still theoretical issue. If similar actions had been undertaken to address the equally hysterical cries of “Global Cooling" just 20 years ago, we would not enjoy a vibrant economy and the economic opportunity that we do today. Rational and honest debate over the issues is imperative prior to forming any government policies on such a matter. SBSC applauds the efforts of the Small Business Committee in the face of the disingenuous campaign to ensure ratification of this treaty, and the "implementation without ratification” already well underway. Additionally, SBSC hopes this Committee will get to the bottom of the clear violation of the letter and the spirit of the Freedom of Information Act, and demand compliance with SBSC's request. Here are the one-page descriptions and a summary list of proposed additional actions for the Climate Change Action Plan. They include all 39 proposals received from OPPE and OAR over the past two weeks. Each one-pager provides. a brief description of the proposed option and information on the timing required to introduce und implement the option; • estimated emissions reductions from the option; · estimated economic costs of the option; • expected legal, funding, timing and political issues associated with the option; and If you have any questions about the one-pagers, please contact me at 260-5492 er Bob |