APPENDIX B

Examples of Form Letters Submitted to the Proposed 

Tailoring Rule Docket

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Appendix B:

Examples of Form Letters Submitted to the Proposed Tailoring Rule Docket

Form Letter 1 .................................................................................................................................. 1

Form Letter 2 .................................................................................................................................. 2

Form Letter 3 .................................................................................................................................. 3

Form Letter 4 .................................................................................................................................. 4

Form Letter 5 .................................................................................................................................. 5

Form Letter 6 .................................................................................................................................. 6

Form Letter 7 .................................................................................................................................. 7

Form Letter 8 .................................................................................................................................. 8

Form Letter 9 .................................................................................................................................. 9

Form Letter 10 .............................................................................................................................. 10

Form Letter 11 .............................................................................................................................. 11

Form Letter 12 .............................................................................................................................. 12

Form Letter 13 .............................................................................................................................. 13

Form Letter 14 .............................................................................................................................. 14

Form Letter 15 .............................................................................................................................. 15

Form Letter 16 .............................................................................................................................. 16

Form Letter 17 .............................................................................................................................. 17

Form Letter 18 .............................................................................................................................. 18

Form Letter 19 .............................................................................................................................. 19

Form Letter 20 .............................................................................................................................. 20

Form Letter 21 .............................................................................................................................. 21

Form Letter 22 .............................................................................................................................. 22

Form Letter 23 .............................................................................................................................. 23

Form Letter 24 .............................................................................................................................. 24

Form Letter 25................................................................................................25
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Form Letter 1

EPA Docket Center, EPA West (Air Docket)

Attention Docket ID No. EPA-HQ-OAR-2009-0517

U.S. Environmental Protection Agency

Mailcode: 2822T

1200 Pennsylvania Avenue, NW

Washington, DC 20460

To Whom It May Concern:

I oppose the EPA's Proposed Rule entitled "Prevention of Significant Deterioration and Title V 

Greenhouse Gas Tailoring Rule." 

This rule is based on faulty and discredited science, and if passed, it would raise energy prices to 

unprecedented levels, in the middle of the most severe economic downturn since the Great 

Depression. 

Please do NOT implement this Proposed Rule. Thank you.
B-2

Form Letter 2

Attn: Docket ID No. EPA-HQ-OAR-2009-0517

I would like to bring to your attention that the Environmental Protection Agency's (EPA) 

"tailoring rule" is fatally flawed. EPA is implementing the "tailoring rule" because it understands 

that regulating greenhouse gases using the Clean Air Act leads to "absurd results." Instead of 

trying to change plain language of the Clean Air Act, EPA should not regulate greenhouse gases.

Currently the Clean Air Act requires the EPA to regulate facilities with the potential to emit 250 

tons per year of a regulated pollutant. With regards to carbon dioxide and greenhouse gases, this 

poses an absurd problem because over one million facilities have the potential to emit more than 

250 tons per year of carbon dioxide. As the U.S. Chamber of Commerce explained, "This 

includes 25 percent of the country's office buildings, 50 percent of all lodging, 37,000 houses of 

worship, 17,000 farms, and virtually every building in the manufacturing sector." (See A 

Regulatory Burden: The Compliance Dimension of Regulating C02 as a Pollutant"). The 

average cost of obtaining a permit is over $125,000 (EPA, Information Collection Request for 

Prevention of Significant Deterioration and Nonattainment New Source Review (40 C.F.R. Parts 

51 and 52), August 2008). Requiring businesses to obtain the necessary permits would not only

increase costs, but, it would create more economic uncertainty and increase the incentives for 

business to leave the United States for areas in the world that provide a more profitable 

environment.

From the EPA's perspective, regulating over one million facilities would bog down EPA's permit 

process and require increased administrative costs. To band aid this perceived problem, EPA is

proposing to "tailor" the Clean Air Act to only regulate facilities which emit more than 25,000 

tons per year because regulating over one million facilities would lead to, in EPA's words, 

"absurd results."

The EPA is trying to rewrite the Clean Air Act in an attempt to circumvent “absurd results.” 

This is an incorrect application of the ideology of the Clean Air Act. Congress clearly intended 

EPA to regulate all facilities with the potential to emit more than 250 tons per year. Thus it is not 

an absurd result for EPA to regulate millions of facilities which emit air pollution. The problem 

occurs when EPA tries to use the Clean Air Act to regulate greenhouse gases. This is because 

the Clean Air Act was not designed to regulate carbon dioxide or the other greenhouse gases.

Instead of trying to argue that applying Congress' plain language is absurd, EPA should not 

regulate greenhouse gases. Regulation of green house gases by the EPA will lead to great 

economic hardship and it would create very little environmental benefits. We need jobs and 

economic growth, not new regulations on millions of facilities.
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Form Letter 3

As a US citizen and BP employee, I am concerned about your recent proposed rule to require 

large industrial facilities that emit greenhouse gases (GHGs) to obtain permits under the Clean 

Air Act and demonstrate use of best available control technologies (BACT). I believe this 

proposal could cause unintended and adverse consequences in terms of permitting chaos and 

delay, and may impede important energy sector projects from moving forward in a timely 

manner.

The United States, not merely BP, needs these projects to continue as scheduled so America can 

utilize America`s energy. I believe that a better approach to the command-and-control approach 

under the Clean Air Act, would be to utilize a sound market-based mechanism for addressing 

GHGs.

Congress is currently considering market-based approaches to address climate change. The 

legislative process should continue without being encumbered by EPA mandates that would 

interfere with a market based approach. I urge the EPA to reconsider its proposal to move 

forward with a Clean Air Act permitting approach.
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Form Letter 4

The Environmental Protection Agency`s (EPA) proposed `tailoring rule` poses a serious threat to 

our nation`s economic recovery. While the stated intention is to regulate large facilities that emit 

more than 25,000 tons of carbon, in reality the rule opens the door for regulation of greenhouse 

gases from smaller manufacturing plants, energy facilities, hospitals, farms, libraries and even 

American homes. This will impose costly economy-wide regulation that EPA will not be 

equipped to handle.

Congress, not the EPA, should address the climate change issue through public and transparent 

debate, leading to a comprehensive federal policy that will achieve environmental results while 

inflicting no economic harm.

At a time when our economy is attempting to recover from our nation`s worst recession since the

Great Depression, this proposed rule would cost jobs in America and undermine our country`s 

ability to remain competitive globally.

Thank you for the opportunity to express my views on this proposed rule which will play a 

significant role in our nation`s energy policy.
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Form Letter 5

The 1970 Clean Air Act is not an appropriate vehicle to regulate greenhouse gases.

To apply the 1970 Clean Air Act to greenhouse gases the EPA would have to regulate 

1.2 million businesses, manufacturers and farms, according to a study by the U.S. 

Chamber of Commerce. This regulation would place a crippling burden on the country.

Any attempt to “tailor” the 1970 Clean Air Act to regulate greenhouse gases from 

stationary sources that have the potential to emit more than 25,000 tons per year is a

clear violation of the black letter law, which states that major stationary emitters are 

classified as “stationary sources with the potential to emit 250 tons or more of any 

pollutant.” 

Moreover, the “tailoring” is unlikely to hold, with zealous state regulators and deeppocketed green litigation groups finding sympathetic judges. Once greenhouse gas 

regulations under the 1970 Clean Air Act are put into effect, it will likely be impossible to 

limit them only to large emitters. 

The Agency’s rationale for the “tailoring rule” is that “absurd results” and “administrative 

necessity” justify exempting most of the entities that would otherwise be regulated. 

When applying a law produces absurd results, the law should not be applied—it’s that 

simple.

I urge you not to regulate greenhouse gases under the 1970 Clean Air Act, which is 

clearly the wrong vehicle for greenhouse gas regulation. Both because it is likely to 

prove ineffective and because it is legally questionable, I oppose the “tailoring rule” as 

proposed in EPA-HQ-OAR-2009-0517. As a member of Americans for Prosperity, I 

urge you instead to defer to Congress to decide whether and how to regulate 

greenhouse gases.
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Form Letter 6

US Environmental Protection Agency

To US EPA Environmental Protection Agency,

I Support EPA Regulation of the Biggest Polluters

Dear EPA,

I support EPA regulation for the biggest polluters. It is imperative for so many reasons that we 

forcefully regulate these polluters. The cost of their pollution is incurred by the public. The 

public that is most exposed and vulnerable to these big polluters are the undeserved and people 

in poverty.

Pollution increases health related costs which will eventually bankrupt the country if the status 

quo prevails. Greenhouse Gas emissions will potentially have devastating effects on society, the 

well to do and the poor.

It is our obligation as citizens of the United States that these large polluters are prevented from 

passing on the costs associated with their pollution to the public. To allow this injustice would 

not be American, capitalism or socialism; it would just be inhumane. I urge you to regulate the 

biggest polluters.

Thank you,
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Form Letter 7

Thank you for your historic action, in response to the Supreme Court's decision in Massachusetts 

v. EPA, recognizing that global warming pollution imperils human health and welfare. Your 

tremendous leadership in reclaiming compliance with the law is rooted in strong science.

Climate change is one of the most crucial problems facing the nation and the world today. We 

also need to recognize the scientific imperative for policy action. I applaud your common-sense 

proposal to require big emitters -- large new and upgraded power plants and industrial emitters --

to use the best solutions in lowering their heat-trapping pollution.

Your proposal will ensure the extensive capital investments in the nation's largest new sources of 

global warming pollution are harmonized with the need to reduce greenhouse gases thereby 

avoiding costly retrofits after the fact while advancing new clean energy technologies.

I appreciate that EPA is prioritizing the biggest sources of heat-trapping pollution, namely the 

ones that emit more than 25,000 tons of carbon dioxide emissions annually. I also support your 

decision to shield small sources from regulation, so that we can focus the nation's resources on 

cost-effective reductions from big emitters. That makes a great deal of sense. By setting a 

25,000-ton threshold -- comparable to the annual energy use of about 2,200 homes -- the 

proposal makes clear that individual homes and small businesses would not be covered by this 

program (despite scare-mongers claims to the contrary).

Finally, I agree with you that it would be even better for Congress to pass legislation creating a 

program that comprehensively addresses climate change and clean energy solutions. But EPA's 

smart policies are a foundation for strong Congressional action. And, until Congress acts, it's 

vital that the nation deploy innovative, protective policies to reduce global warming pollution 

and to ensure that America is winning the race to clean energy innovation in the global 

marketplace.
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Form Letter 8

Dear Administrator Jackson,

When doctors in an ER triage an extreme case they act immediately and decisively on ONLY the 

most serious and immanently life-threatening issues. Nothing else matters until the patient is 

stabilized. We are approaching a triage decision for Global Warming on Earth. Life as we know 

it is bleeding out. We can see exactly where to act - now YOU just need the courage to do it.

The United States has created the vast majority of the historical greenhouse gas emissions, and 

even today is just barely eclipsed by China's total annual output. But China has 4 times the 

population of the US, which effectively means each US citizen STILL generates about 4 times 

the pollution as the Chinese.

The United States and China together create some 40% of current emissions worldwide, and it is 

painful and ironic that for yet ANOTHER year neither of us will ratify Kyoto. We can't control 

China, so what is the best place for US decision-makers to focus triage efforts to stop the lifethreatening hemorrhage that we created? The obvious target is the mega-polluters. If we know 

half of US emissions can be plugged at just a few sources, it is a moral imperative that we act on 

that.

Life as we know it is bleeding out. We can see exactly where to act - now YOU just need the 

courage to do it.
B-9

Form Letter 9

I support President Obama's plan to enforce limits on global warming pollution from coal plants 

and other big polluters under the Clean Air Act.

We need to stop letting coal plants and other big polluters off the hook so we can create clean 

energy jobs and solve global warming.
B-10

Form Letter 10

I am submitting comments in favor of the U.S. Environmental Protection Agency's intention to 

regulate large sources of global warming emissions [Docket ID number: EPA-HQ-OAR-2009-

0517].

The 2007 report of the Intergovernmental Panel on Climate Change unequivocally concluded 

that our climate is warming, stating with at least 90 percent certainty that the warming of the last 

several decades is primarily due to human activities.

There is much at risk from unchecked global warming. Our nation and the world can expect 

more extreme heat, severe storms, dangerous flooding, rising sea levels, threats to agriculture, 

and increased rates of plant and animal species extinctions.

The longer we wait, the harder and more costly it will be to limit climate change and to adapt to 

those impacts that will not be avoided. Right now, only a handful of sources, including coal 

power plants, are responsible for more than half of all of the global warming emissions in the 

United States.

It makes sense to regulate the largest emissions sources to ensure the United States gets the 

largest emissions reductions as quickly as possible. The EPA's proposed rule to reduce 

emissions from these large-scale polluters under the Clean Air Act is a crucial first step--by

targeting the worst offenders, the rule will quickly cut global warming emissions while still 

helping our economy grow.
B-11

Form Letter 11

Dear Administrator Jackson,

As a person of faith, called to care for God’s people and creation, I applaud you for recognizing 

the importance of regulating green house gases to protect human health and the environment. I 

understand that the buildup of these pollutants in the atmosphere is the major cause of global 

climate change, which poses serious risks to God’s people and God’s Creation. I urge you to act 

quickly to implement strong new rules to require big smokestack industries to meet modern 

pollution standards for carbon emissions when new facilities are constructed or existing facilities 

are significantly modified.

Climate change is one of the most critical moral issues of our time. We must respond 

compassionately, intelligently and quickly to the challenge of climate change. Thank you for 

your leadership in recognizing greenhouse gases as a form of air pollution. Please continue to 

lead by quickly implementing strong new rules designed to control global warming pollution 

effectively, protecting God’s Creation and God’s people and communities across the US and 

around the world from the impacts of global climate change.
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Form Letter 12

Unchecked, climate change will impact every person on earth – whether by rising seas, droughts, 

storms, floods, rising snow pack lines, and wildfires -- or by the massive costs that accompany 

them. Scientists tell us that we may still have time to prevent such a future, but we can only do 

so by controlling the pollution from the world's biggest sources of greenhouse gases and ramping 

up clean, renewable sources of energy like wind and solar.

Coal-fired power plants are by far the largest producer of global warming pollution in America, 

and by regulating the harmful emissions produced by America's coal-fired plants the Obama 

Administration has a real opportunity to make sure that our environment is safer for future 

generations.

Please take the necessary steps to ensure that all sources of global warming emissions in the 

United States are regulated, reduced and controlled, including the coal industry. As a first step, 

please finalize a strong rule to require big smokestack industries to meet modern standards for 

global warming pollution when new facilities are constructed or existing facilities are 

significantly modified.
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Form Letter 13

It's time to take back control of our energy future. By harnessing the power of the wind and the 

sun, we can cut global warming pollution and transition to clean energy sources that don't harm 

the environment, never run out, and create good paying new jobs here in the United States. To 

succeed, we must require coal-fired power plants - America's largest single source of global 

warming pollution - and other big smokestack industries to stop polluting with impunity.

As a first step, please finalize a strong rule to require big smokestack industries to meet modern 

standards for global warming pollution when new facilities are constructed or existing facilities 

are significantly modified.
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Form Letter 14

Dear Administrator Jackson,

I appreciate your efforts to cut dangerous global warming pollution with the tools at your 

disposal under the Clean Air Act, and urge you to guarantee that companies building or 

expanding big carbon pollution sources will use the best available control technology. A handful 

of industries -- like power plants, oil refineries, cement kilns and other big factories -- are 

responsible for more than half of the nation's global warming pollution.

Two years ago the Supreme Court issued a landmark ruling that the Environmental Protection 

Agency has the authority and responsibility under the Clean Air Act to reduce dangerous global 

warming pollution. The EPA's proposed new rule would use the Clean Air Act to curb pollution 

from these large sources, while at the same time assuring small sources (like millions of mom 

and pop businesses) that they will not be regulated.

This is nothing new or complicated. Big power plants and other new sources have been required 

to use the best available control technology for other pollutants, like sulfur dioxide, for decades. 

The proposed new rule would use the same tools to curb global warming emissions when 

companies build or expand big pollution sources.

Cleaning up the largest and dirtiest pollution sources first is a logical and cost-effective way to 

reduce our global warming pollution. I urge you to finalize a strong rule that will hold industry

accountable, clean up our air and protect our health.
B-15

Form Letter 15

Dear Administrator Jackson,

As an American concerned with the future of my country's climate and natural resources, I jump 

at the chance to regulate our nation's largest polluters.

Please let it be noted that I strongly support the EPA's proposed rule to require America's largest 

industrial facilities to obtain Clean Air permits. 
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Form Letter 16

I am writing in support of EPA's proposed greenhouse gas tailoring rule. This rule will regulate 

carbon dioxide and other greenhouse gases from big sources of air pollution, and require stateof-the-art controls on new and modified polluters. This proposal is an essential step that will 

help to reduce greenhouse gas pollution and address climate change.

Regulating greenhouse gases is the right thing to do. Thank you. With these and other actions, 

EPA is finally taking greenhouse gases and climate change seriously. I support these efforts and 

the tailoring rule.
B-17

Form Letter 17

Dear EPA Administrator Jackson,

A relatively small number of factories and coal-burning power plants emit more than half of the 

carbon dioxide discharged into the atmosphere by the United States. The most effective way to 

cut global warming pollution is to require those big polluters to make significant reductions in 

their dangerous emissions.

Carbon dioxide emissions from coal combustion constitute a major source of global warming 

gases. Controlling those emissions is absolutely essential if we are to minimize the worst 

consequences of global warming: heat waves, climate instability, storms, extreme weather, 

flooding, and drought. These changes in climate will result in grave threats to human health: 

increased heat stroke and respiratory diseases; increased water-borne and vector-borne diseases; 

decreased food production; shortages of potable water; population displacement, and growing 

conflict and war.

As a member of Physicians for Social Responsibility, I support the EPA in reducing global 

warming emissions and regulating first those polluters who are responsible for the largest share 

of the problem. This approach will allow swift reductions in emissions of carbon dioxide and 

will also contribute to reducing emissions of toxic pollutants that damage the respiratory, 

cardiovascular and nervous systems.
B-18

Form Letter 18

Dear Administrator Jackson,

Right now only a handful of sources, including coal power plants, are responsible for more than 

half of all the global warming pollution in the United States. These mega-polluters should be 

held responsible for their share.

EPA's Big Polluters rule is a major step toward holding these facilities accountable. By focusing 

on cleaning up the largest sources of global warming pollution first, emissions can be cut 

quickly, while still helping our economy grow.

EPA is right to seek the most bang for its regulatory buck by taking on the big polluters first. 

The Big Polluters rule will result in real pollution reductions and help spur growth and 

development of clean energy technologies. I support EPA's decision to efficiently and 

effectively get us on track towards a cleaner future.
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Form Letter 19

Big smokestack industries account for more than half of all the carbon pollution produced in the 

United States. A strong rule by the EPA requiring heavy polluters to meet modern emission 

standards when expanding or building new facilities is a critical first step in cutting America's 

emissions. The EPA's recently issued proposed rule on big carbon emitting polluters would 

result in the quick, significant carbon pollution reductions America needs to assert its leadership 

in the global transition to a green economy.

Critical to this rulemaking is the creation of a reporting system that will finally provide 

businesses the data necessary to compare and control emissions as well as inform federal 

strategies on national emissions reduction. Accurate and credible data on domestic carbon 

polluters is necessary for the United States to address the climate crisis on the domestic and 

international stages.

The effects of climate change are already being felt across the United States. Now is the time to 

put the United States on track toward a low-carbon future that is safe for America's people, 

wildlife, and natural environments. Please finalize a strong rule demanding transparency and 

accountability from the nation's largest carbon polluters.
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Form Letter 20

The Alliance for Climate Protection (Alliance) applauds EPA's proposed rule to limit greenhouse 

gases (GHGs) from the largest sources of U.S. global warming pollution. The Alliance believes 

this proposed rule represents a common sense approach to deliver cost-effective GHG reductions 

through the Clean Air Act's proven Prevention of Significant Deterioration (PSD) and Title V 

permitting programs.

The Alliance supports swift regulatory action to reduce GHG emissions from big polluters, such 

as coal-fired power plants and large industrial emission sources. Focusing on the largest polluters 

first makes economic and environmental sense, and through the promotion of GHG reduction 

technologies, will help transition America to a clean energy economy.

The Alliance informed its members about this proposed rule, and provided them with an 

opportunity to support the draft regulation. Interested members expressed support for the 

proposal by agreeing to endorse a petition that would be submitted to EPA as public comments.

The petition states, "I support the EPA's proposal to reduce greenhouse gas emissions from our 

biggest polluters. By doing so, we can help transition to a clean energy economy."

In total, 39,526 Alliance members endorsed the petition. Their names and information are 

included in the USB drive enclosed with this letter.

The Alliance commends EPA's approach represented in this proposed rule that would eliminate 

illogical and costly outcomes and would deliver real GHG reductions through the Clean Air Act. 

The Alliance supports this proposed rule and encourages EPA to finalize a rule that requires big 

polluters to clean up their act.
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Form Letter 21

Dear Administrator Jackson,

I support President Obama's plan to enforce limits on global warming pollution from coal plants 

and other big polluters under the Clean Air Act.

Please finalize a strong rule to require big smokestack industries to meet modern standards for 

global warming pollution when new facilities are constructed or existing facilities are 

significantly modified.
B-22

Form Letter 22

I support the effort to enforce limits on green house gas emissions from Coal plants under the 

Clean Air Act. This is a critical first step to minimizing climate change due to human activities. 

Thank you.
B-23

Form Letter 23

I support President Obama's plan to enforce limits on global warming pollution from coal plants 

and other big polluters under the Clean Air Act.

We need to stop letting coal plants and other big polluters off the hook so we can create clean 

energy jobs and solve global warming.
B-24

Form Letter 24

Dear Administrator Jackson,

I support President Obama's plan to enforce limits on global warming pollution from coal plants 

and other big polluters under the Clean Air Act.

Please finalize a strong rule to require big smokestack industries to meet modern standards for 

global warming pollution when new facilities are constructed or existing facilities are 

significantly modified.
B-25

Form Letter 25

Dear EPA Administrator Jackson:

It's time to take back control of our energy future. By harnessing the power of the wind and the 

sun, we can cut global warming pollution and transition to clean energy sources that don't harm 

the environment, never run out, and create new, local jobs. But we will only succeed if we 

require coal-fired power plants-America's largest single source of global warming pollution-and 

other big smokestack industries to stop polluting with impunity. As a first step, please finalize a 

strong rule to require big smokestack industries to meet modern pollution standards for carbon 

when new facilities are constructed or existing facilities are significantly modified .