U.S. CHAMBER OF COMMERCE

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GRC Project2011 Year in Review

Copyright © 2011 by the United States Chamber of Commerce. All rights reserved. No part of this publication may be reproduced or transmitted in any form—print, electronic, or otherwise—without the expressed written permission of the publisher.

The U.S. Chamber of Commerce is the world’s largest business federation representing the interests of more than 3 million businesses of all sizes, sectors, and regions, as well as state and local chambers and industry associations.

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The Global Regulatory Cooperation (GRC) Project is pleased to share the following year end report that highlights the policy work that took priority in 2011. We would like to express our deep appreciation for the generous financial support granted by member companies as well as acknowledge a big debt of gratitude for those individuals who have lent their time and talents to the cause. 2011 Highlights The GRC Project which seeks to align trade, regulatory, and competition policy in support of open and competitive markets continues to have six areas of focus:

• International Role, Responsibility, & Coordination of U.S. Regulatory Agencies • Better Regulation & Regulatory Cooperation • Standards • Competition Policy & Antitrust • State Capitalism & State-Owned Enterprises • Investment

In large measure the GRC Project was founded on the idea of developing new trade disciplines in emerging areas of trade policy and in many ways 2011 marked the most successful effort towards achieving this goal to date. Original text drafted by the Chamber became the starting point and served as a substantial basis for the U.S. government proposed text in the TPP negotiations in three areas:

• Due Process in Antitrust Investigations – Secured new disciplines in the U.S. text of an FTA related to due process in antirust proceeding. This was a significant development given the institutional resistance faced from the DOJ and FTC on including anything antirust related in a trade agreement, and to a lesser extent some substantive heel-dragging in support of raising the bar with regard to due process internationally.

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• Regulatory Coherence - Secured a new chapter outlining regulatory best practices as part of the U.S. proposed structure for an FTA. While these obligations aren’t subject to dispute settlement, they represent a significant advance in bridging the divide between domestic regulatory policy and its relationship to trade. Best evidence for this is that despite being well within the body of U.S. administrative law, the text met resistance from U.S. regulators as they didn’t want to see the two policy worlds (regulatory and trade) brought closer together.

• State-Owned Enterprises – Secured a whole series of new disciplines as well as transparency requirements on state commercial enterprise that are in competition with private commercial actors. The text addresses behavior that distorts competition such as preferential financing, regulatory advantage, or SOE purchases or sales of goods and services in the market. The development of the U.S. text proposal required multiple drafting efforts by the private sector, led by the Chamber, as well as more than 100 meetings with officials across the Hill and Administration.

In 2011 the other most significant accomplishments included:    

• ACUS International Regulatory Cooperation Recommendation – Roughly a year ago, the Chamber initiated the idea of Administrative Conference of the U.S. (ACUS) ACUS reviewing and updating its 1991recommendation as part of the GRC Project’s efforts to redefine the international role, responsibility, and coordination of U.S. regulatory agencies. The Chamber was pleased to partner with ACUS in April of this year for a joint program that served to make the case for the ACUS review. Since that time the GRC Project worked closely with ACUS and provided several rounds of input into a background report prepared by ACUS as well as the final recommendations voted on in December. The adoption of the revised recommendation represents the most forward-thinking vision articulated to date as to how U.S. regulators should seek to support the removal of non-tariff barriers.  

 • OMB Engagement – As a direct result of GRC project’s engagement with the

Office of Information and Regulatory Affairs (OIRA) and the Office of the U.S. Trade Representative (USTR) the administration is working to redefine the international role and responsibility of U.S. regulatory agencies. In its annual report to Congress on the cost and benefit of federal regulations, OMB recommended for the first time that U.S. regulators cooperate with regulators

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from key trading markets to support trade and exports. In addition, OIRA and USTR issued a guidance memo to U.S. regulatory agencies outlining the regulatory tools at their disposal to ensure regulations enhance, rather than obstruct, trade.

• Thwarting the EU NAMA TBT Proposal – The GRC Project helped to lead a

campaign to sink the EU NAMA TBT proposal which would have designated three specific standard setting bodies as being the sole developers of designated “international” standards. Had the effort been successful, the three designated standard development organization would have become a choke point for standards development, severely limiting the use of standards in regulation in accordance with TBT requirements would have been severely limited.

• Antitrust India and China Focus – In the antitrust area, the GRC Project was successful, working through the U.S.-India Business Council in getting significant changes to the proposed draft merger guidelines that were most problematic as India’s merger regime came into force for the first time in 2011. We also were able to significantly shape the drafting of India’s national competition policy, which is likely to be finalized in 2012. Here, arguably our biggest success was getting references to intellectual property being labeled an essential facility removed, preventing justification of future regulatory compulsory licensing decisions. We will have to remain vigilant that these references remain out of the draft going forward. We also continued active support of the China team and worked with them as the Chamber continued to expend significant resources in support of appropriate enforcement of China’s AML.    

• Investment – The GRC Project underwrote and developed in partnership with the China team a series of draft schedules as annexes to a potential future BIT with China. These draft schedules include “horizontal” measures that affect all foreign investment and four industry sectors: (1) information technology; (2) food, pharmaceuticals, and medical devices; (3) renewable energy; and (4) media and content. The schedules are based on publicly available information regarding measures enacted by China’s central government as of December 31, 2010. They have been prepared in anticipation of the continuation of BIT negotiations and to better understand the landscape of investment challenges in these sectors.

 

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Finally, the GRC Project which primarily works closely with and through the regional teams in the international division to advance key GRC policy priorities expanded itself. In September 2011, we added Adam Schlosser. Adam comes to the GRC Project with domestic and international regulatory experience having been a Presidential Management Fellow working for the General Service Administration and within the Department of Agriculture, having served as its TBT delegate to the WTO. Adam has been an excellent addition and will be responsible for significantly building out our regulatory and standards work in 2012. A Brief Look Ahead In addition to building on these and other critical successes of 2011, the GRC Project has plans under way for 2012 which include:

• Standing up of an International Regulatory & Standards Working Group to better guide and direct our work in this area.

• Launching the Investment Policy Forum to steer the Chamber’s international investment work which will advance both sides of the Foreign Direct Investment equation.

• Advocating and developing trade policy in support of regulatory cooperation and best regulatory practices with regard to cross-border free flows of data

• Offering support and guidance of two new regulatory dialogues launched with Canada and Mexico.

• Working with ACUS to implement its new recommendations to drive a paradigm shift in the mindset of U.S. regulators as it relates to U.S. competitiveness in a global economy.

More detailed highlights from 2011 follow. If you have questions on anything in this report please feel free to contact either if us. Sincerely, Sean Heather Adam Schlosser Executive Director Senior Manager 202-463-5368 202-463-5580 sheather@uschamber.com aschlosser@uschamber.com

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GRC Project

Year in Review -2011-

International Role, Responsibility, & Coordination of U.S. Regulatory Agencies April – As a result of three years of advocacy before OIRA, OMB’s draft annual report to Congress on the cost and benefit of federal regulation signaled, for the first time, as one of six recommendations, which regulatory agencies engage in regulatory cooperation with key trading partners in support of trade and exports. This is a significant statement from OMB given that regulators have often argued that such efforts are not part of their mandate. April – Hosted a conference on the international dimension of U.S. regulatory agencies with the Administrative Conference of the United States (ACUS) as the co-sponsor. The program discussed a 1991 ACUS recommendation on how U.S. regulatory agencies should engage foreign counterparts as well as a panel of regulators and industry leaders discussing the opportunities and challenges to greater engagement for U.S. regulators in support of trade and investment. May – OIRA & USTR jointly issued a long awaited memo, originally suggested by the GRC Project dating back to the last months of the Bush Administration, which highlights the international dimension of existing regulatory guidance to agencies and how it should be used when promulgating regulation in order to promote and facilitate trade. This memo is not only important as the Chamber looks to redefine the international role and responsibility of regulatory agencies, but also serves to better support our messaging to foreign regulators. The GRC Project worked with OIRA and USTR to get the memo released from its hold and finally issued. June – As a result of the conference in April and the GRC Project’s outreach, ACUS agreed to adopt as part of its program of work a formal review and update of its 1991 recommendation on international regulatory cooperation. August – At the request of the GRC Project, Chairman Issa of the House Government Oversight Committee sent a letter to the GAO requesting a study on the international role and responsibility of regulatory agencies. GAO agreed to begin to look into these issues in early in 2012.

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September – In working with ACUS on their updated draft recommendation, the GRC project offered a series of detailed comments to ACUS’ first draft of new recommendations on international regulatory cooperation ahead of its September 30th meeting of its regulatory working group. The Chamber comments were well received and the working group endorsed the direction of ACUS. October – The GRC Project continued its strong involvement in shaping the update to ACUS’s international regulatory cooperation recommendation by submitting additional comments in advance of the October 25th meeting of the Committee on Regulations. The GRC Project was the only private sector member in attendance and was allowed to freely participate, representing the interest of the business community. November – Hosted the public session of the U.S. – EU High Level Regulatory Cooperation Forum featuring a debrief from Heinz Zoureck of DG Enterprise and Michael Fitzpatrick, Associate Administrator of OIRA. Stakeholders in attendance asked questions and also provided suggestions to help direct future U.S. – EU regulatory cooperation efforts. December – The United States – Canada Regulatory Cooperation Council announced a Joint Action Plan calling for increased and formalized specific sectoral-based cooperation between U.S. and Canadian regulators. The working plan incorporates input from the GRC Project and will focus on, among other topics, agriculture and food, transportation, and health and personal care products. December – The GRC Project drafted a letter to the ACUS director and Assembly to encourage adoption of a final recommendation that encourages U.S. regulators to look to remove unjustified non-tariff barriers, whenever practicable. Based in large part on our outreach, the Assembly voted to finalize the version supported by the GRC Project, nudging U.S. regulators to begin to innovate and think outside of the box regarding their international regulatory cooperation activities. Better Regulation/Regulatory Cooperation/Standards January – Hosted Dr. Patrick Gallagher, Undersecretary of Commerce for Standards and NIST Director, with ASTM to discuss the federal register notice on evaluating the government’s role in standard setting, standards and U.S. competitiveness, as well as the relationship between standards, IP, and competition policy. February – Served as the leading voice from the business community and worked closely for many months in 2010 with the USTR to craft a new chapter on regulatory

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coherence for the TPP. The text of that chapter was completed and put through a very difficult inter-agency process before being tabled at the TPP negotiations. The text requires a central coordinating body to provide a level of control and consistency over regulatory agencies, calls for a series of regulatory best practices and enhances transparency among other things. March – As a follow-on to hosting Gallagher, the GRC Project drafted and submitted Chamber comments in response to a federal register notice on the government’s role in standard setting, what standards mean in terms of U.S. competitiveness, international cooperation, and competition enforcement. March – Sponsored the APEC Subcommittee on Standards and Conformance conference on Regulatory Best Practices, advised on the agenda of the two day program, and served as moderator for one of the opening sessions. March – Organized and hosted the 2nd U.S.-EU Transatlantic Insurance Symposium, with over 130 people in attendance. The audience was at an extremely senior level, featuring Evan Greenberg, CEO of Ace; Bill Toppeta, President MetLife International; Mark Laidlaw, EVP of AEGON NV; Joel Steinberg, Chief Actuary NYL, and multiple other EVPS, SVPs, and GCs. All the leading players from Europe, both corporate and government, as well as 10 leading state insurance commissioners, and Congressman Ed Royce were together to discuss how to ensure regulatory developments on either side of the Atlantic can be made compatible. April – Drafted and organized roughly 20 signatories to a letter to the Administration in opposition to the EU NAMA TBT proposal which would have designated only three standards bodies globally to be deemed as international standards developers. The proposal would have cemented an advantage for the EU standards setting bodies, created new choke points for standard setting globally, and limited choice and competition. The EU has for now dropped the proposal. April – Drafted and submitted comments to a Federal Register Notice requesting potential agenda items for separate regulatory dialogues recently formed with Mexico and Canada. June – Drafted and submitted comments to a Federal Register Notice requesting potential agenda items for U.S.-EU regulatory cooperation. June – Co-hosted in Brussels with BUSINESSEUROPE the public session of the U.S.-EU High Level Regulatory Cooperation Forum.

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June – Commissioned a paper Determining Compatible Regulatory Regimes by John Morrall, currently an economic consultant and Affiliated Senior Scholar with the Mercatus Center of George Mason University. He also worked for six Presidents on regulatory policy in the Executive Office of the President from 1975 until September 2008. The paper argues for a new approach to regulatory cooperation with Europe, a fresh look at MRAs, and the deployment of a new methodology for conducting transatlantic regulatory impact assessments on regulations. July – Organized and hosted a series of events with the EU team on U.S.-EU cooperation in support of Transatlantic Week held in Washington, D.C. July – Organized and hosted a series of meetings/forums with the Brussels office in support of the Morrall paper. Discussions featured Morrall with the business community in Brussels as well as the EU Commission. September – In the TPP in support of regulatory coherence, the GRC Project worked with the NZ government to table a proposal that would close a gap in the U.S. text and introduce a best practice regarding risk based regulation. In addition, a number of bilateral were held during the Chicago round in support of the TPP regulatory coherence text. September – Drafted a letter to the EU Commission expressing concerns with its consideration of changes to its government procurement policy and the unintended effects proposed changes might have on U.S. companies doing business in the EU market as the EU looks to address reciprocity concerns largely related to China. September – Moderated and lead a discussion at the first ever Consumer Product Safety Summit for North America. The panel discussion was on industries ability to “harmonize thyself.” October – Organized in coordination with the Chamber’s Center for Capital Market’s Competitiveness (CCMC) a roundtable discussions with Director McRaith of the newly created Federal Insurance Office (FIO) at Treasury. The discussion focused on its plans both domestically and internationally. October – Hosted and helped to organize a two day meeting between the American National Standards Institute (ANSI) and their counterparts that make up the European Standards Organizations. The meetings focused on standards setting cooperation and regulators recognition of standards in the areas of e-mobility, e-vehicles, energy management, smart grid, intelligent transportation systems,

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cargo/container security, aviation security, CBRN security, and the EC Mandate M/487. The session also included remarks from TEC co-chairs Froman and De Gucht. November – Submitted comments to the National Science and Technology Council’s report on U.S. Federal Engagement on Standard Setting. The comments echoed the reports support for the U.S. standard setting process, one that is voluntary, private-sector, and consensus based, but also suggested additional clarity related to IPR. November – Submitted comments to the Department of Commerce, International Trade Administration, explaining concerns over the EU’s standard setting strategy, published in June 2011. The GRC voiced concerns with the EU’s top-down approach and will also seek to enlarge the opportunities for U.S. entities to participate in the EU standard setting process. November – Moderated a panel at the U.S. – EU High Level Regulatory Cooperation Forum about “building brides” between the U.S. and EU approaches to standard setting. The GRC Project pushed the EU participants to explain some of the EU’s positions that may adversely affect U.S. interests. November – Underwrote and co-hosted with TABD the Transatlantic Economic Council reception. November – Submitted a letter to the TEC requesting that it reinvigorate an earlier commitment to address insurance regulatory matters given the creation of the FIO granting authority for Treasury to negotiate international agreements for insurance matters. December – Sponsored and helped to organize a discussion, at the GW Regulatory Studies Center, with business leaders, academics, and high-level government representatives about the GRC Project sponsored paper by John Morrall about Trans-Atlantic Regulatory Impact Assessments. December – Led a meeting with the Chamber’s CCMC and member companies with Director McRaith and the FIO to share priorities with regard to the federal register request for feedback on the state based regulatory system for insurance. This discussion informed the drafting of Chamber comments to the federal register prepared and filed later in the month.

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Competition Enforcement/Antitrust January – Briefed Embassy Staff of ASEAN TPP Members on the Chamber’s TPP Competition Chapter Priorities including both due process and SOE related concerns. January – Met with DG Competition to discuss plans for due process reforms within the EU and its commitment to further OECD discussions on the subject later in the year. March – Organized private sector participation for the 2nd year in a row in the APEC Competition Policy and Law Group meeting to discuss important procedural practices in both merger and non-merger antitrust proceedings. April – Significantly advanced the due process provisions afforded in antitrust proceeding in the context of trade agreements. As a result of a sizeable and multifaceted advocacy campaign, resistance to expanding the due process provisions in KORUS and concerns about antitrust enforcement being included in trade agreements was successfully overcome. New far reaching and robust due process protections are now USG policy for text in trade agreements. This text is now being negotiated in the TPP. May – Successfully modified poorly written and potentially extremely problematic merger guidelines in India. The GRC Project working through the U.S. India Business Council launched a multi-pronged lobby campaign including hosting meetings/calls with the Chairman of the Competition Commission of India to ensure India’s guidelines in support of its new merger regime would only review significant transactions that take place in India. May – Co-hosted with the China team a training program on the interface between antitrust and IP for a distinguished group of leading and up and coming Chinese judges. June – The GRC Project had been coordinating pressure on the EU Commission for the past few years to institute due process reforms in its antitrust proceedings, something which has been met with a great deal of reluctance. A series of initial reforms were announced at the end of 2009, but Commissioner Almunia in a speech announced a series of additional reforms to address the calculation of fines as well as an expanded role for the hearing officer who will better serve as an internal check and balance.

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June – Unlocked the EU freeze on discussing due process further in the OECD with the aim of drafting OECD best practices. The OECD agreed to bring up due process with regard to judicial review of antitrust enforcement decisions. Further, due process was formally put forward to be included in the International Competition Network, the global body of antitrust regulators, as a program of work in 2012. This entire due process body of work has been globally orchestrated by the GRC Project for the past three years. June – Hosted what turned out to be a farewell speech by AAG Varney where she summed up the direction of U.S. antitrust policy both domestically and internationally a week prior to her announcement that she would be leaving for private practice. July – Organized and hosted senior high-level briefings for both AAG Varney and Chairman Leibowitz ahead of their joint trip to China to sign an MOU on antitrust cooperation. A similar debrief was held with Leibowitz upon his return. July – Met with the Philippines Embassy to express concerns over the vagueness and harshness of draft competition/antitrust laws. Shared with them our concerns for the direction the law was currently headed and our support for a modern competition act that reflects international norms. Provided follow-up materials that outlined our chief concerns. Aug/September/October – Worked with the AmCham in the Philippines regarding the draft competition act going through its legislature. Provided the AmCham with substantive and technical expertise in assessing both version of the bills ahead of key meetings the AmCham had organized with the key Filipino Senate Committee Chair and the Speaker of the House. August – Submitted comments to the federal register in response to the FTC interest in standards and patent hold-up. The comments expressed concern with regard to what should be a very limited role of antitrust regulators and our concerns with the signals potentially sent internationally by the FTC’s workshop. August – Organized a small group meeting with Commissioner Ramirez at the FTC raising our ongoing concern that the FTC needs to be more conscientious of how its domestic messaging is perceived abroad. The FTC March IP report attracted a fair amount of attention by foreign authorities at the same time the USG looks to advance IPR abroad. August – Drafted a response for USIBC to submit as comments on India’s draft National Statement on Competition Policy. The policy statement had several

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troubling aspects with regard to government procurement and the view that IP should be viewed as an essential facility. In part as a result of the comments and follow-up work, the draft statement has and continues to be refined. A final version isn’t expected till later in the year. September – Submitted a letter to the federal register in response to the FTC interest in regulatory review. In the letter we again urged that the FTC provide regulatory guidance with regard to its use of Section 5 beyond the bounds of traditional antitrust law. October – The GRC Project with the Chamber’s China team jointly hosted a debrief with DOJ and FTC following the BRIC antitrust conference. October – The GRC Project drafted and jointly submitted with BUSINESSEUROPE an article for Competition Policy International marking the 20th anniversary of U.S.-EU cooperation. The article reflected on the shift between the bilateral relationship to the multilateral relationship of global antitrust. October – Helped to draft the outline of BIAC comments ahead of the OECD Competition Committee meeting on the role of judicial review of competition agency decisions as part of our ongoing due process efforts. November – Worked with both the Senate Commerce committee as well as the House Judiciary sub-committee to raise the profile of and get questions asked during both the confirmation hearing for Chairman Leibowitz and Commissioner Olhausen as well as the oversight hearing of the FTC and DOJ. Points of emphasis were raised on FTC Section 5, differences in merger review between the two agencies, and IP and antitrust policy. December – Underwrote part of the financial costs associated with the AML training session in China on horizontal and vertical restraints. State Capitalism/SOEs January – Traveled to Brussels to visit with key official in DG Trade, DG Enterprise, DG Competition, and the European Parliament to share with them the last two years of research and policy development work the GRC Project has done in support of developing new potential disciplines on SOEs in a trade, investment, and competition context. This visit was timely given the Commission’s new authority to negotiate investment treaties and internal discussions regarding inbound investment screens. Experience with serving on the review of the U.S. model BIT was also shared.

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February – Sponsored and steered the development of a paper jointly with CSI on new trade and investment disciplines on SOEs to ensure competitive neutrality in the context of the TPP agreement. A follow-up campaign was launched to raise the profile of the issue in support of the paper across the inter-agency in anticipation of an opportunity to introduce new disciplines in the TPP. March – Sponsored a major conference on Competition Law and the State: International and Comparative Perspectives in Hong Kong. The conference looked through an antitrust enforcement lens of the role antitrust regulators should play in policing public sector restraints of trade including anti-competitive regulation and SOEs. March – Provided financial support and worked with the Chamber’s China team to conduct an analysis of the new China investment screening regime for reviewing foreign investment. This is of critical concern as such a screen is likely to extend beyond legitimate national security concerns, especially since China has signaled its interest to use its antitrust laws to promote industrial policies in screening mergers and acquisitions. April – Co-authored with Stephen Kho at Akin Gump a two part article that appeared in International 360 entitled Checkers and Chess? Facing State Capitalism which argued for an examination in the deficiency of existing trade and investment disciplines against state commercial actors and potential new approaches to support competitive neutrality by governments in its relationship to both state and private commercial actors. April – Drafted and coordinated the signing by six leading business associations a letter to the inter-agency expressing urgency and support for developing a robust and comprehensive text on SOEs to be included in the TPP. May – Co-sponsored and supported the organization of an AmCham Beijing program held at the Chamber on “China and the SOE Challenge”. A panel featured much of the policy work the GRC Project has been leading on for the last couple of years. May – Completed an extensive process that culminated in draft text to address SOEs for the TPP. That text was shared with USTR and served as a basis for internal deliberations. July – Suggested and secured Bob Kimmitt for the CSI Services Summit to speak on SOEs. Also advised and helped prepare his remarks.

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September – Presented at the Chicago round a presentation on the merits of including and addressing SOEs in the TPP. In addition, several bilateral meetings were held with negotiators from various TPP countries on the SOE issues and the anticipated USG text. A statement of general, but important support by NZ during the round for the SOE issue was a direct result of the Chamber’s behind the scene efforts. September – Successfully sought a delay in the original USG text on SOEs for the TPP as the text was too rushed and hurried by the inter-agency in an effort to complete ahead of the Chicago round. Subsequent to the delay, the GRC Project led an effort to revamp its previously submitted text over a couple of marathon drafting sessions at the request of the USG. September – Drafted comments for USCIB and BIAC ahead of the OECD Investment Committee meeting where the SOE issue was raised. In addition to the comments, the GRC Project supplied a short background paper which was also included in the OECD submission. October – After nearly a year worth of work and managing a small coalition including CSI, NFTC, ACLI and USCIB, the GRC Project was able bring the USG text on SOEs to a successful conclusion ahead of the Lima round of the TPP. This represented hundreds of hours of work and countless meetings on the Hill and across the inter-agency to ensure that the groundbreaking text put the SOE issue on solid footing. November – Co-organized and hosted a program on policy prescriptions to addressing anticompetitive market distortions that must be better addressed in order to accelerate progress of the National Export Initiative. The event was done in collaboration with the International Roundtable on Trade & Competition. November – Working with a number of other associations, the GRC Project signed a letter to the State Department and conducted follow-up outreach out of concern for how the State Department might represent U.S. interests at the Universal Postal Union ( UPU). Given the leadership of the State Department on the SOE issue it was important to ensure that U.S. position in the UPU was consistent with both Congressional mandates and the messaging State has championed in regard to a level playing field between SOEs and private commercial actors. Investment March – Underwrote and developed in partnership with the China team a series of draft schedules as annexes to a potential future BIT with China. These draft

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schedules include “horizontal” measures that affect all foreign investment and four industry sectors: (1) information technology; (2) food, pharmaceuticals, and medical devices; (3) renewable energy; and (4) media and content. The schedules are based on publicly available information regarding measures enacted by China’s central government as of December 31, 2010. They have been prepared in anticipation of the continuation of BIT negotiations and to better understand the landscape of investment challenges in these sectors. August-December – Worked to lay the groundwork of the launch of the Investment Policy Forum in 2012 which will raise the profile of the Chamber’s work with respect to investment policy.

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GRC Project2011 Year in Review