2025 M Street, NW, Suite 350, Washington, DC, 20036 Phone: (202)
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April 25, 2005

The Honorable Karen Harbert

Assistant Secretary for Policy and International Affairs

U.S. Department of Energy

1000 Independence Avenue, SW

Washington, D.C. 20585

By email:
[1605bguidelines.comments@hq.doe.gov](mailto:1605bgeneralguidelines.comments@hq.doe.gov)

Dear Assistant Secretary Harbert:

I write on behalf of the eight member associations of the Alliance for
Climate Strategies (ACS) to request a minimum thirty (30) day extension
to the public comment period for the proposed interim final rule for the
"Voluntary Reporting of Greenhouse Gases (1605b) Program" and the
referenced Draft Technical Guidelines.

The Alliance for Climate Strategies (ACS) is a broad-based advocacy
coalition of industry sectors created to exemplify the principle that
voluntary actions are an effective means of reducing greenhouse gas
emissions, and to demonstrate that the ingenuity and technological
expertise of American industry can achieve meaningful reductions in
greenhouse gas emissions. The members of ACS include the following
national trade associations: American Chemistry Council, American Forest
and Paper Association, American Petroleum Institute, American Road and
Transportation Builders Association, Edison Electric Institute, Nuclear
Energy Institute, National Mining Association and the National Rural
Electric Cooperative Association. ACS maintains, as a condition of
participation in the group, a requirement that all participants be
engaged in GHG management partnership agreements with the federal
government, or be working to establish a GHG management partnership. All
principal ACS members are participants in the Climate VISION program.

ACS appreciates the opportunity to submit written comments on both the
proposed revised General Guidelines interim final rule and the
associated Draft Technical Guidelines. However, we note that the May 23,
2005 deadline for the submission of written comments on these
significant and voluminous proposals does not provide sufficient time to
develop thoughtful and constructive comments. As announced, the
Department of Energy (DOE) plans to host a two-day workshop beginning on
April 26, 2005 to further explain the proposed General Guidelines and
the Draft Technical Guidelines and to answer questions and receive input
from stakeholders and other interested parties. Similarly, DOE and the
Department of Agriculture will host a workshop in early May to focus
more specifically on elements of the Draft Technical Guidelines. ACS
applauds and appreciates these opportunities, yet we note that the
scheduling of the workshops will afford us and others only twelve (12)
business days to develop comments with the benefit of the knowledge and
information to be exchanged at the events. This imposes a particularly
tight timetable for association and coalition comments which need to
reflect the consensus views of broad memberships.

In addition, while the introduction to the proposed General Guidelines
states that "few" changes have been made since the first proposal was
released, a cursory review of the proposed interim final General
Guidelines indicates instead that substantial changes have been made.
Members of ACS request this extension to provide more opportunity to
review and evaluate these significant changes and, as stated above,
benefit from the information to be exchanged at both of the public
workshops.

Finally, we note that the while the proposed schedule for completion and
publication of the interim final General Guidelines and the Technical
Guidelines differ, the interrelation between the two is intricate and
inseparable. We expect that the scheduled workshops will help all
stakeholders develop a better understanding of the interrelation and a
greater ability to provide constructive comments, yet the ability to do
so significantly will depend on an opportunity for further evaluation
that can be afforded only by an extension of time to submit written
comments. Given the extended period of time that elapsed between the
time that the Department of Energy published its draft General
Guidelines and these interim final General Guidelines and Draft
Technical Guidelines, we see no reason why stakeholders should not be
allowed sufficient time to digest these proposals completely and provide
constructive responses and suggestions

Thank you in advance for the opportunity to make this request for a
minimum 30-day extension to submit written comments on the interim final
General Guidelines and the proposed Draft Technical Guidelines. We hope
you will agree that the Department's decision to provide an extension to
the deadline for comments on the initial Draft General Guidelines
significantly improved the quality of those comments and will most
certainly do so in this case.

Sincerely,

Glenn Kelly

Executive Director