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White House Chief of Staff Jeff Zients

Dear Mr. Zients, The undersigned state and regional associations representing sectors and industries across the U.S. economy urge you to maintain the existing National Ambient Air Quality Standards for particulate matter (PM2.5). A proposed revision to this standard is under review by the White House Office of Information and Regulatory Affairs. This proposal could put nearly 40% of the U.S. population in areas of nonattainment,1 risking jobs and livelihoods across the nation and making it significantly more difficult to obtain permits to build new factories, bridges, and roads that will power our economic growth. Implementation of the Infrastructure Investment and Jobs Act, the CHIPS and Science Act, and the Inflation Reduction Act have the potential to infuse substantial investments into our states and communities, but all of that is now threatened by the permitting restrictions that would flow from this proposal. This regulation will put nearly every goal to encourage manufacturing in our states and regions at risk and could prevent the American economy from reaching its full potential.

Our members have innovated and worked with regulators to lower PM2.5 emissions significantly. The Environmental Protection Agency’s 2022 Air Trends and National Emissions Inventory report shows that PM2.5 concentrations have declined by 42% since 2000,2 driven by major emissions reductions from both mobile sources and the power sector. As a result, our air is cleaner than at any point in modern times. The current PM2.5 standard is set at 12 μg/m3; yet, some are advocating a standard as low as 8 μg/m3—which is lower than naturally occurring levels in many parts of the country. This proposal is also far more stringent than the guidelines in place in Europe, where the current EU standard is 25 μg/m3 more than twice the current level in the U.S.

The vast majority of PM2.5 emissions in the U.S. (84%) come from wildfires, road dust, and other nonpoint sources.3 As we have seen this year, the Canadian wildfires have had a more dramatic effect on air quality in the U.S. than any industrial sources. Nonattainment designations will be influenced heavily by these past three years of wildfire emissions, making compliance with existing standards—let alone any new standards—much more difficult. In many areas, there may not be sufficient offsetting emission-reduction options, and as a result, investments across the country could be brought to a grinding halt. Even without the new air quality data, the EPA’s Regulatory Impact Analysis failed to identify sufficient controls for all areas of the country to attain any of the proposed standards.4 In fact, the EPA has already proposed to disapprove a California state plan for failing to demonstrate that it can attain the current 2012 standard.5

Despite the vast majority of emissions coming from nonpoint sources, the cost of complying with this regulation will fall solely on our members. It will impact our ability to create jobs, innovate, and invest in America. A recent analysis conducted by Oxford Economics and commissioned by the National Association of Manufacturers found that if the proposed PM2.5 regulations are implemented, GDP will be reduced by nearly $200 billion and nearly 1 million current jobs will be put at risk. In addition, these numbers may actually understate the problem because they do not include the most recent air quality data.

Notably, these economic impacts will be localized rather than evenly dispersed across the country. Some states will be hit harder than others, but all states will miss out on new manufacturing facilities and jobs due to the permitting roadblocks mandated as a result of tighter standards. Under the proposed rule, close to 650 counties, equivalent to 22% of all U.S. counties, could be placed out of attainment. Even in areas that would meet the EPA’s proposed standards, current PM2.5 background levels are so close to the proposed standards that no room would be left for new economic development, virtually ensuring severe economic consequences. The inability to invest in America as a result of this proposal creates perverse outcomes, in which new facilities could be located in foreign countries with more lax air standards due to these administrative hurdles—undermining the economic and environmental goals of your administration.

In practice, these proposed standards are aspirational in that they are set at background levels, which effectively means that any industrial emissions could put a locality out of attainment. While our members continue to innovate, making cleaner products and pioneering cleaner processes, no one can comply with a regulation that sets the standard at effectively zero.

We strongly encourage your administration to maintain the existing standards, which will ensure that we remain among the countries with the cleanest air in the world while also supporting much-needed economic growth.

Sincerely,

Chris V. Isaacson, President and CEO, Alabama Forestry Association

Patrick Cagle. President, Alabama Mining Association

Kati Capozzi, President and CEO, Alaska Chamber

Deantha Skibinski, Executive Director, Alaska Miners Association

Danny Seiden, President and CEO, Arizona Chamber of Commerce and Industry

Randy Zook, President and CEO, Arkansas State Chamber of Commerce

Lance Hastings, President and CEO, California Manufacturers & Technology Association

Loren Furman, President and CEO, Colorado Chamber of Commerce

Chris DiPentima, President and CEO, Connecticut Business & Industry Assn, Inc.

Lisa B. Himber, President, Maritime Exchange - Delaware River & Bay

Brewster B. Bevis, President, Associated Industries of Florida

Lloyd Avram, President and CEO, Georgia Association of Manufacturers

Sherry Menor-McNamara, President and CEO, Chamber of Commerce Hawaii

Alex LaBeau, President, Idaho Association of Commerce & Industry

Benjamin J. Davenport, Executive Vice President, Idaho Mining Association

Mark Denzler, President and CEO, Illinois Manufacturers’ Association

Mark A. Biel, Chief Executive Officer, Chemical Industry Council of Illinois

Brian Burton, President and CEO, Indiana Manufacturers Association

Mike Ralston, President, Iowa Association of Business and Industry

Alan Cobb, President and CEO, Kansas Chamber of Commerce

Frank Jemley III, President and CEO, Kentucky Association of Manufacturers

Tucker Davis, President, Kentucky Coal Association

Will Green, President and CEO, Louisiana Association of Business and Industry

Greg Bowser, President and CEO, Louisiana Chemical Association

Tommy Faucheux, President, Louisiana Mid-Continent Oil and Gas Association

Mike Moncla. President, Louisiana Oil and Gas Association

Adam Haddox, Executive Director, Louisiana Pulp and Paper Association

Patrick Strauch, Executive Director, Maine Forest Products Council

Mary Kane, President and CEO, Maryland Chamber of Commerce

Brooke Thomson, President, Associated Industries of Massachusetts

John Walsh, President and CEO, Michigan Manufacturers Association

Jami Des Chenes, Executive Director, Michigan Chemistry Council

Jason Geer, President and CEO, Michigan Oil and Gas Association

Jim Holcomb, President and CEO, Michigan Chamber of Commerce

Doug Loon, President and CEO, Minnesota Chamber of Commerce

John McKay, President and CEO, Mississippi Manufacturers Association

Ray McCarty, President and CEO, Associated Industries of Missouri

Todd O’Hair, President and CEO, Montana Chamber of Commerce

Bryan Slone, President, Nebraska Chamber of Commerce & Industry

Ray Bacon, Executive Director, Nevada Manufacturers Association

Michael Skelton, President and CEO, Business & Industry Assoc. New Hampshire

Michele N. Siekerka, Esq., President and CEO, New Jersey Business & Industry Association

Carla J. Sonntag, President and CEO, New Mexico Business Coalition

Heather C. Mulligan, President and CEO, The Business Council of New York State, Inc.

Harold King, President, Council of Industry (Hudson Valley)

Peter Ahrens, Executive Director, Buffalo Niagara Manufacturing Alliance

Gary Salamido, President and CEO, NC Chamber

Ross M. Smith, President, North Carolina Manufacturers Alliance (NCMA)

Arik Spencer, President and CEO, Greater North Dakota Chamber

Ryan Augsburger, President, Ohio Manufacturers Association

Steve Stivers, President and CEO, Ohio Chamber of Commerce

Jenn Klein, President, Ohio Chemistry Technology Council

Pat Tiberi, President and CEO, Ohio Business Roundtable

Robert Brundrett, President, Ohio Oil and Gas Association

Chad Warmington, President and CEO, State Chamber of Oklahoma

Brook A. Simmons, President, The Petroleum Alliance of Oklahoma

Angela Wilhelms, President and CEO, Oregon Business & Industry

David N. Taylor, President and CEO, Pennsylvania Manufacturers' Association

Darlene J. Robbins, President, NE Pennsylvania Manufacturers & Employers Assoc.

Matt Gabler, Executive Director, Pennsylvania Forest Products Association

Peter Vlahos, President, Pennsylvania Aggregates & Concrete Assoc. (PACA)

John Olson, President, Pennsylvania Builders Association

Luke Bernstein, President and CEO, Pennsylvania Chamber of Business & Industry

Steven Kratz, President, Pennsylvania Chemical Industry Council

Rachel Gleason, Executive Director, Pennsylvania Coal Alliance

Daniel Weaver, President and Executive Director, Pennsylvania Independent Oil and Gas Association

Ted Harris, Executive Vice President, Pennsylvania Petroleum Association

Matt Smith, President, Greater Pittsburgh Chamber of Commerce

David M. Chenevert, Executive Director, Rhode Island Manufacturers Association

Bob Morgan, President and CEO, South Carolina Chamber of Commerce

Sara H. Hazzard, President and CEO, South Carolina Manufacturers Alliance

David Owen, President, South Dakota Chamber of Commerce and Industry

Kwinn Neff, President, South Dakota Mineral Industries Association

Bradley Jackson, President and CEO, Tennessee Chamber of Commerce

Candace Dinwiddie, Executive Director, Tennessee Forestry Association

Chuck Laine, President, Tennessee Mining Association

Tom Midyett, President. Tennessee Paper Council

Glenn Hamer. President and CEO, Texas Association of Business

Richard A. “Tony” Bennett, President and CEO, Texas Association of Manufacturers

Todd R. Bingham, President and CEO. Utah Manufacturers Association

Brian Somers, President, Utah Mining Association

Rikki Hrenko-Browning, President, Utah Petroleum Association

William Driscoll, Vice President, Associated Industries of Vermont

Brett Vassey, President and CEO, Virginia Manufacturers Association

Kristofer Johnson, President and CEO. Association of Washington Business

Rebecca McPhail, President, West Virginia Manufacturers Association

Kurt Bauer, President and CEO, Wisconsin Manufacturers and Commerce

Robert Jensen, Executive Director, Alliance of Wyoming Manufacturers

Travis Deti, Executive Director, Wyoming Mining Association

Andrew Shall, President, Graphic Media Alliance (OH, MI, KY)

Keith A. Christman, President, Decorative Hardwoods Association

Jaret Gibbons, Executive Director, Appalachian Region Independent

 

CC: The Honorable Lael Brainard, Director of the National Economic Council

The Honorable Michael Regan, Administrator, EPA

Steve Ricchetti, Counselor to the President

Ali Zaidi, National Climate Advisor

John Podesta, Counselor to the President

Gene Sperling, Counselor to the President

October 13, 2023

Every October, manufacturers throughout the Pittsburgh region and beyond, including our Pennsylvania Chemical Industry Council (PCIC) members, celebrate National Manufacturing Month and the positive contributions manufacturing has on our society. The economic impacts are significant. According to the American Chemistry Council, the chemical and plastics industries inject over $14 billion, support over 90,000 direct and indirect jobs, and generate hundreds of millions of dollars in taxes annually.

The impacts on our daily lives may not be as obvious. How the products we purchase from a retail shelf or online service are made is often overlooked. Manufacturing starts with chemistry, which is the building block for nearly every product we use daily. When you think about it, chemistry is responsible for nearly every healthcare product, as the building blocks for cleaner energy options, high-performing building materials, food packaging, electronics, clothing, vehicles and more.

Modern society needs continued chemical and plastics production and demand is expected to increase. The good news is that every year, manufacturers are finding new and innovative ways to make their products more sustainable. Our PCIC members are advancing sustainability, expanding advanced recycling and decarbonizing supply chains, driving substantial environmental benefits.

While innovative companies are leading the way to harness new technological innovations to reduce emissions, reduce waste, and recycle more, legislators and regulators at the state and federal levels must enact sound policies that advance sustainability efforts. Forced mandates and ultimatums stifle innovation. A better path is taking a collaborative approach.

Our members, including those in Western Pennsylvania, aren’t waiting for others to lead the way when it comes to sustainability and environmental stewardship.

Covestro has partnered with the University of Pittsburgh to unveil the first graduate-level program dedicated to furthering the circular economy. Shell Polymers Monaca utilized over 10 miles of recycled pipes and the equivalent of three million recycled grocery bags worth of plastics helped build the roads at the facility. Pittsburgh-headquartered LANXESS has developed a clear strategy and launched several major projects to become climate-neutral by 2040. BASF has entered into power purchase agreements with solar and wind projects that will make up more than 25% of the company’s North American electricity consumption.

Our industry’s leadership in this space is that it doesn’t come at the expense of economic growth and good-paying jobs. It only bolsters our status as a manufacturing powerhouse supported by a strong supply chain with a rich industrial history of innovation. For over a century, the Pittsburgh region has been home to some of the most cutting-edge industrial companies, such as Wabtech, whose locomotives and equipment keep the global rail industry moving, and U.S. Steel, whose American-made steel products support our nation’s auto sector, infrastructure projects, and home appliance manufacturing. The region’s thriving supply chain ensures that this heritage of manufacturing dominance with a focus on environmental sustainability and innovation will continue for centuries.

Balancing economic growth with environmental protection requires policymakers in Harrisburg and Washington, D.C. to take constructive steps to partner with industry to develop policies and regulations that empower investments in innovation and sustainable solutions.

In 23 states, including Pennsylvania, legislation around advanced recycling, has paved the way for our members to utilize circular chemical feedstocks as inputs to manufacture new products. Enabling legislation also is generating significant new investments in advanced recycling development.

However, at the national level, the EPA is taking a different approach in its Draft National Strategy to Prevent Plastic Pollution. While well-intentioned, it fails to account for the transformational benefits of advanced recycling and risks sending U.S. chemical and plastics jobs overseas. Congress has also taken a significant interest in the role plastics and advanced recycling play in American manufacturing and environmental stewardship.

As we celebrate Manufacturing Month in 2023, we need to look to the future and chart a path forward that brings innovators, regulators, and policymakers together to develop smart policies, grounded in reality that drive real environmental solutions while unleashing economic growth. Working together, we can move toward a more sustainable future led by the men and women of our industry who are paving the way for a better tomorrow, today.

Steven Kratz is president of the Pennsylvania Chemical Industry Council.

July 27, 2023

For Immediate Release  

Harrisburg, Pa. –  “The Pennsylvania Chemical Industry Council commends the Environmental Hearing Board for dismissing a legal attempt to call into question Pennsylvania’s advanced recycling legislation that was signed into law by former Democratic Governor Tom Wolf in 2020. 

Plastics are critical to every aspect of modern life, from health care products, medical equipment, clothing, and food packaging, to energy efficiency products, renewable energy, battery storage, microchips, and electric vehicles. Our members invest hundreds of millions of dollars to advance new technologies and real solutions to reduce, reuse and recycle more. 

Reducing plastic waste while manufacturing the products consumers rely on every day will take collaboration and innovative solutions. Economic growth and sustainability can work hand-in-hand. However, continued litigation brought forward by groups like the Clean Air Council will not lead us to real environmental progress. 

We are encouraged that Pennsylvania’s bipartisan advanced recycling legislation that was signed into law has now been affirmed by the Environmental Hearing Board.” 

For Background

Pennsylvania is one of 24 states nationwide to appropriately regulate advanced recycling technologies as manufacturers and not waste facilities. This important distinction provides regulatory certainty to attract new economic investment such as Encina’s proposed $1.1 billion facility while ensuring full compliance with PA DEP and EPA permitting requirements.   

Contact: 

Steve Kratz, President, PCIC

This email address is being protected from spambots. You need JavaScript enabled to view it.

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