September 23, 2003

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 the U.S. Government's effort to ratify and implement legislation related to the Stockholm Convention and Long Range Toxic Air Pollutants (LRTAPs) Treaties covering Persistent Organic Pollutants (POPs).

As we communicated previously in ARCC letters to the Senate and the Department of State (Feb. 10, 2000; Sept. 22, 2000; and May 24, 2001), ARCC support of the Stockholm Convention and related Treaties is based on achieving 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.

Soon, critical implementation decisions will be made at the global level that could impact U.S. business and markets. It is imperative that the U.S. ratify these treaties so that the U.S. will be directly involved in these decisions. Failure to act quickly on this matter risks sidelining U.S. input into critical deliberations.

In order for the U.S. 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 that the Senate should provide "Advice and Consent" on any proposed changes or additions to the Treaties. Without the procedural safeguards of the "opt-in" and Senate oversight (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. U.S. POPs Implementing Legislation should give flexibility to the U.S. Environmental Protection Agency (EPA) with regard to how a substance is regulated in the U.S. In determining what if any domestic action is appropriate for a chemical that has been added to one of the POPs 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 acted to regulate a substance being proposed for addition to the Treaties, further U.S. regulation may not be necessary. As another example, the U.S. might support a different method for regulating a proposed substance than the method supported by some others at the international level.

3. U.S. Implementing Legislation must ensure EPA's discretion and protect U.S. sovereignty. Therefore, we respectfully urge you to:

Effective U.S. ratification and implementation of the Stockholm and LRTAP POPs Treaties is supported by the vast majority of U.S. industries, environmental groups and scientific organizations. The unions and companies of ARCC urge you to support ratification and implementation of these Treaties, taking into account the above considerations.

Sincerely,

John J. Barry President Emeritus International Brotherhood of Electrical Workers Co-Chair, ARCC		C.T. "Kip" Howlett, Jr. Executive Director Chlorine Chemistry Council Co-Chair, ARCC

CC: Copy furnished to all Committee Members.