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Boiler MACT Coalition Letter on Senate-House Bills

Boiler MACT Coalition Letter on Senate-House Bills

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Published by: National Association of Manufacturers (NAM) on Jul 20, 2011
Copyright:Attribution Non-commercial


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July 20, 2011The Honorable Susan CollinsU.S. Senate413 Dirksen Senate Office BuildingWashington, DC 20510The Honorable Ron WydenU.S. Senate223 Dirksen Senate Office BuildingWashington, DC 20510Dear Senators:We are writing to express our united and strong support for legislation you areintroducing today and for H.R. 2250,
the “EPA Regulatory Relief Act of 2011,”
bipartisanlegislation to address the serious concerns that remain with EPA
Boiler MACT rules.As they exist today, the final Boiler MACT rules will have serious economic impacts on avast array of facilities across the industrial, commercial and institutional sectors. Theserules place at risk tens of thousands of high-paying manufacturing jobs that our nationcannot afford to lose.As finalized, the Boiler MACT rules are unaffordable, just as the proposed rules were.The rules are not achievable for real-world boilers across the range of fuels andoperating conditions. EPA also has created a presumption that materials commonlyused as fuels are wastes subject to the extremely costly and stigmatizing incineratorstandards. This would not only impose billions of dollars in unreasonable costs, but italso would cause millions of tons of valuable materials to be diverted to landfills andreplaced with fossil fuel
a bad result for the environment.As EPA has acknowledged, the rules were finalized with serious flaws because EPAwas forced to meet a strict court-ordered deadline. The final Boiler MACT rule alonewould cost over $14 billion in capital for the manufacturing sector, plus billions more inannual operating costs. Complying with the incinerator standards could cost severalbillion dollars more in capital.Legislation is needed to resolve serious uncertainties and vulnerabilities, including to:
ensure the rules are stayed for an adequate and certain period, as EPA’s current
administrative stay is being challenged in court;
allow EPA adequate time to re-propose the rules and get them right, includingtime for stakeholders to conduct more emissions testing and to avoid mistakesthat occur when rulemakings of this scope and importance are rushed andbecome vulnerable to legal challenge;
provide direction and support for EPA to use the discretion it already has underthe Clean Air Act and Executive Order 13563 to add flexibility and make the rulesachievable;
clarify that using non-hazardous materials as fuels does not result in boilersbeing treated as incinerators; and

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