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July
13, 2004
Dear Representatives Barton, Dingell, Gillmor and Solis: On behalf of the Alliance for the Responsible Use of Chlorine Chemistry (ARCC), an alliance of major American unions and companies concerned with jobs and investments in the chlorine chemical industries, we wish to express our support for Congress's efforts to implement the Stockholm Convention and Long Range Toxic Air Pollutants (LRTAPs) Treaties covering Persistent Organic Pollutants (POPs). The Senate has acted, and now we respectfully urge the House to act. The U.S. must ratify these treaties so it can participate directly in forthcoming treaty implementation decisions that may impact U.S. businesses and markets. Our key concerns are highlighted below. As we communicated in ARCC letters to the Senate and the Department of State (Feb. 10, 2000; Sept. 22, 2000; May 24, 2001, and Sept. 23, 2003), ARCC's support of the Stockholm Convention and Treaties is based on three goals: consideration of the legitimate interests of America's workers and companies; identification and adoption of global environment protections; and the promotion of economic growth for both developed and developing nations. To implement the POPs Treaties and protect legitimate U.S. interests, ARCC believes that: 1. The United States should exercise its right to use the "opt-in" provision outlined in the Treaties, and Congress should have an appropriate role in considering any changes or additions to the POPs Treaties. This is critical in order to preserve U.S. sovereignty and ensure that any changes to the Convention are consistent with U.S. law and U.S. interests. Without the procedural safeguards of the "opt-in" - fundamental to the U.S. system of checks and balances - the U.S. could be obligated to take action domestically that it does not support. 2. In determining whether domestic action is appropriate for a chemical that has been added to the Treaties, the U.S. should make an explicit domestic determination based on clear criteria. The U.S. should not be forced to take domestic regulatory action if it is not warranted. For example, if the U.S. has already regulated a substance being proposed for addition to the Treaties, further U.S. regulation may not be necessary. Or, the U.S. might support a different method to regulate a proposed substance than the method supported by some others at the global level. U.S. ratification and implementation of the Stockholm Convention and the Treaties is supported by most U.S. industries, environmental groups and scientific organizations. The ARCC urges you to support ratification and implementation, taking into account the above considerations. Sincerely,
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