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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 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

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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.


SBSC is joined by numerous concerned interests in believing this treaty will cause

unfair, unnecessary and unprecedented harm to the U.S. economy, while non

participating 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.

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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 wiz:ks. 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 cconomic costs of the option;
• expeciéd legal, funding. timing and political issues associated with the caption; and

an overall rating of the option by ils originators, factoring all aspects of the option

discussed above If you have soy questions about the one-pagers, please contact me at 260-8492 er Bob Shackleton ar 760.8988.

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