This article appeared in the January 2020 issue of MiMfg Magazine. Read the full issue and find past issues online.
Two significant regulatory issues are developing which could threaten Michigan’s manufacturing competitiveness and its ability to continue to grow new jobs and retain the state’s existing 628,600 manufacturing jobs.
The first new threat is caused by the international transport of air pollutants into Michigan which automatically trigger increased regulatory burdens on manufacturers. Despite continued reductions in emissions from in-state manufacturers, new and significant cost burdens could be imposed.
The second barrier to competitiveness involves Michigan’s race to set the lowest standards for PFAS and related compounds. The state is moving hastily forward, without fully accounting for the costs of the new regulatory burdens and stretching the bounds of settled science.
International Sources of Air Pollutants
MMA is leading the charge to block increased and ineffective regulations that will result in little or no benefit to Michigan’s air quality. It is increasingly clear that Michigan’s air quality is significantly impacted by emission sources coming from other states and from outside the United States.
Federal Clean Air Act regulations automatically impose regulations on Michigan businesses both statewide and in the state’s 10 ozone nonattainment areas, despite additional controls on Michigan companies which have no impact on the air moving in from out-of-state sources. Michigan’s nonattainment areas would be “bumped up” to the “moderate” designation of nonattainment in 2021. These regulations will increase costs and even limit new individual growth through emission offset requirements.
MMA is investigating a rarely used exemption available under the Clean Air Act, under section 179(b), to account for the international contribution. In August, MMA led a Great Lakes delegation of manufacturing organizations to meet with the U.S. EPA Region V Administrator Cathy Stepp to discuss the effect of international impact. MMA is also working with Michigan Department of Environment, Great Lakes and Energy (EGLE) to examine out-of-state contributions.
Rational and Science-Based Approach to Emerging Chemicals like PFAS
With increasing attention on PFAS and related compounds, Michigan is moving very quickly to establish some of the lowest drinking water standards in the nation. The cost of these regulations will be substantial for citizens, communities and employers.
When states set standards beyond federal levels, manufacturers become concerned about an unbalanced regulatory cost structure compared to other states. The costs imposed on communities and businesses will likely be substantial. In addition, when new regulations are set at the state level, manufacturers are concerned about whether the standards are rooted in settled science. MMA will be filing formal comments when the state sets the public hearing schedule.