coal power plants to close, cutting jobs and putting a squeeze on an abundant and affordable source of energy.
• Waters of the United States (WOTUS) Rule: The EPA’s WOTUS expands federal jurisdic- tion over land features to clas- sify simple ditches, a stream on property that only flows when it rains, and a pond that happens to be near another covered water as federally regulated tributaries. The rule has left businesses uncertain about what they can do with their property, and it was finalized with- out the required regulatory impact analyses.
• Ozone Rule: The EPA issued an ozone rule that imposes billions of dollars of costs on state and local governments, and more than 950 U.S. counties will be in violation of it. This “nonattainment” designa- tion would hamper development in local economies across the nation. Businesses, including metalcasting facilities, could be denied federal air permits and/or prevented from expanding.
• Silica Standard: In March 2016, the Occupational Safety & Health Administration (OSHA) finalized a new regulatory structure for the control of crystalline silica, includ-
ing drastically reducing the silica permissible exposure limit (PEL). The rule’s assumed economic and technical feasibility and justifica- tion does not jive with the foundry industry’s estimate that it will ulti- mately cost more than $2.2 billion dollars annually. For more informa- tion on this rule, see page 29. A frequently utilized rulemak-
ing process of “sue and settle” is also unsettling to metalcasters. Trough this process, organizations sue federal agencies for failing to meet a regula- tory deadline or requirement. To settle the case, the government can enter into a consent decree that compels the agency to issue new regulations without going through the traditional rulemaking process of information- gathering from stakeholders. Tis process lacks transparency and costs manufacturers and taxpayers millions of dollars. Tis approach displaces the requirements of the regulatory process that are in place to ensure an open and fair process. Two bipartisan bills have been
introduced to reform and modernize the regulatory system: • The Regulatory Accountability Act (S. 2006/H.R. 185), already passed by the House, would modernize the regulatory process by increasing transparency during the rule devel-
opment process, allowing interested parties to meaningfully participate in the process and making agencies consider alternatives that achieve their objective at a lower cost.
• Sunshine for Regulatory Decrees and Settlements Act (S. 678/H.R. 712), also passed in the House, would bring greater transparency and accountability to the sue and settle process by requiring federal agencies to inform the public when they settle lawsuits. Affected parties would have more opportunity to participate in these agreements.
EPA’s Ozone Standard Te EPA released its new strin-
gent national ozone standard of 70 parts per billion (ppb) on Oct. 1, 2015. Specifically, the rule will put new burdens on the commercial and industrial activity and cause significant portions of the country to fall into nonattainment areas. Industry analysis shows over 950 counties will fall into nonattainment. Nonattainment designation triggers
additional pollution control require- ments, restrictions on new and existing building expansion, and more strin- gent permitting requirements. Tis restriction will apply to manufactur- ing facilities, including metalcasters, as well as new and modified power plants. Metalcasters will not be able to expand production or build a new facility without a significant reduction of emissions or shutdown of opera- tions from other plants in the area. Industry supporters have argued
the new standard is burdensome, costly and disregards the progress the country has made to improve air qual- ity over the last several decades. Key concerns are the ozone rule
Castings would be critical in rebuilding and repairing the nation’s water infrastructure. 34 | MODERN CASTING June 2016
will increase the cost of energy for business in large regions of the country and cause many regions to be “no-growth” zones because they are in nonattainment areas. Te rule also will require installation of the most effective emission reduction technolo- gies without consideration of cost and suspends, in some cases, federally supported highway and transporta- tion projects. Currently, the EPA must review
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