Letters & Comments

Read ACA’s letters and comments submitted to regulatory bodies and elected officials.
Click ‘Read More,’ to open the PDF, with the option for download.

ACA Joint Letter on SEC Proposed Climate Reporting Rule

ACA joined more than 50 other organizations in a letter to Congressional committee leaders on the SEC's proposed a new climate reporting regime that will impose substantial costs on manufacturers and interfere with their efforts to report decision-useful climate information to their investors.

Read More…

ACA Comments on EPA’s PFAS Reporting Rule IRFA

ACA submitted comments to U.S. EPA on the  agency’s Initial Regulatory Flexibility Analysis and Updated Economic Analysis (IRFA) for the proposed rule, Reporting and Recordkeeping Requirements for Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) under the Toxic Substances Control Act (TSCA).

Read More…

ACA, Others Urge EPA to Extend PFAS Reporting Rule Comment Deadline

ACA joined 17 other organizations in a letter to U.S. EPA requesting that the agency extend the comment period for the Initial Regulatory Flexibility Analysis (IRFA) and Updated Economic Analysis for the proposed Toxic Substances Control Act (TSCA) section 8 (a)(7) reporting and recordkeeping rule by 30 days.

Read More…

Letter to Congressional Leadership for Action to Avert a Rail Strike

On Nov. 28, ACA joined more than 400 organizations in a letter to Congressional leadership urging action to avert a rail strike. “While a voluntary agreement with the four holdout unions is the best outcome, the risks to America’s economy and communities simply make a national rail strike unacceptable,” the letter stated. “Therefore, absent a voluntary agreement, we call on you to take immediate steps to prevent a national rail strike and the certain economic destruction that would follow.”

Read More…

ACA Comments on Maine's Second Concept Draft for PFAS

On Nov. 10, ACA submitted detailed comments to the Maine Department of Environmental Protection (DEP) on the Second Concept Draft for regulations implementing the Act to Stop Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Pollution. ACA continues to engage  with Maine DEP to help ensure an accurate understanding of PFAS in products and any associated risks to the public and the environment.

Read More…

ACA Comments on EPA's Proposed RMP Amendments

ACA's Oct. 31 comments to EPA noted that many of the agency's proposed amendments to the RMP rule aim to improve upon prevention program elements of particular types of facilities, promote information availability, and emergency response measures, and that ACA shares EPA’s goal of ensuring people both inside and outside of chemical facilities are safe and prevent any catastrophic chemical accidents. However, some of EPA’s proposed changes (as currently drafted) will not serve to improve the safety within a chemical facility, but rather create significant burdens on a facility that would result in higher costs to the facility with no corresponding improvement in safety.

Read More…

ACA Letter Urges President to Work with Railroads and Unions to Ratify Tentative Agreement

ACA joined more than 300 trade associations in a letter to President Biden urging continued "work with the railroad unions and railroads to ensure that the tentative agreement that you helped broker is ratified by the parties. It is paramount that these contracts now be ratified, as a rail shutdown would have a significant impact on the U.S. economy and lead to further inflationary pressure."

Read More…