Editor’s note: The following letter was sent on August 20 to every member of the U.S. House of Representatives. The effort was spearheaded by the National Association of Manufacturers and supported by more than three dozen business organizations whose names appear at the end of the letter.
August 20, 2002
Recently, members of the House and Senate have sent letters to Environmental Protection Agency (EPA) Administrator Whitman expressing concern about the Administration’s recommendations to modify the Clean Air Act’s New Source Review (NSR) program. We disagree with these letters’ characterization of the environmental impact of the NSR reform package. We believe that the proposed changes to the NSR program, in fact, will result in cleaner air and increased energy efficiency.
EPA has recommended changes to the NSR program in two parts. The first will be issued as a proposed rule, which is expected to clarify definitions for “routine repair and replacement” among other things. This process will go through the formal rulemaking process, including full public notice and comment and, by its very nature, will allow for substantial analysis and a full debate of the issues before the rule takes effect.
The second set of changes will be issued in a final rule. This rule focuses on the “emissions measurement” policy raised in the letter. This rule would also provide incentives for industry to undertake pollution control and prevention projects. These proposed changes have been under consideration by EPA since 1996 and have already been subject to the full public comment and review procedures.
The expected changes on emissions measurement will actually encourage reductions in pollution from manufacturing and other industrial facilities. The rule modifies cumbersome regulations, thereby allowing facilities to install more energy/cost efficient and less polluting technology. Without this rule change, facilities will continue to operate within their permitted levels, but in a less efficient manner. Under no circumstance do the proposed changes allow emissions from a facility to exceed the levels set forth in their clean air permits.
We are concerned that there appears to be an effort to stall the NSR reform process despite wide agreement that the current program is seriously flawed. A delay at this point in the process would be counterproductive because it would continue to discourage facilities from making modifications and undertaking projects that would reduce emissions and improve energy efficiency. Moreover, these capital-intensive projects would be further delayed at a time when every investment decision is critical to the nation’s economic recovery.
We look forward to discussing this matter with you and your staff in the near future.
Adhesive and Sealant Council
Alliance of Automobile Manufacturers
American Architectural Manufacturers Association
American Boiler Manufacturers Association
American Chemistry Council
American Coke and Coal Chemicals Institute
American Forest & Paper Association
American Gas Association
American Iron & Steel Institute
American Petroleum Institute
Association of Equipment Manufacturers
Ceramics Manufacturers Association
Composites Fabricators Association
Cookware Manufacturers Association
Copper and Brass Fabricators Council, Inc.
Council of Industrial Boiler Owners
Edison Electric Institute
Forging Industry Association
Independent Lubricant Manufacturers Association
Industrial Energy Consumers of America
International Sign Association
IPC – The Association Connecting Electronic Industries
Metal Treating Institute
National Association of Manufacturers
National Lime Association
National Mining Association
National Oilseed Processors Association
National Petrochemical & Refiners Association
National Stone, Sand and Gravel Association
Non-Ferrous Founders’ Society
Oklahoma State Chamber of Commerce & Industry
Portland Cement Association
Precision Machined Products Association
Pressure Sensitive Tape Council
Printing Industries of America, Inc.
Society of Glass and Ceramic Decorators
The Adhesive and Sealant Council, Inc.
The Carpet and Rug Institute
The Grocery Manufacturers of America, Inc.
The Ohio Manufacturers’ Association
The Refractories Institute
U.S. Chamber of Commerce