The National Center for Policy Analysis appreciates the opportunity to comment on the President's request to the EPA to reconsider its previous denial of California's 2005 Waiver of Federal Preemption under Section 209(b) of the Clean Air Act. We would like to take this opportunity to caution EPA Administrator Jackson against reversing the denial of the request made by former EPA Administrator Johnson in 2008. There are serious concerns over the legality, regulatory burden, and inevitable market distortions that granting the California waiver would invite. Furthermore, allowing California to set greenhouse gas (GHG) emission standards for passenger cars will have no net effect on greenhouse gas emissions, effectively undermining their purpose in seeking the waiver.