Regulatory: EPA Making Rules In A Vacuum

June 30, 2011

Automotive NewsWire: June 29, 2011

The U.S. Environmental Protection Agency gave final approval yesterday on labeling that will allow the sale of E15 gasoline/ethanol blends for newer vehicles.  The EPA’s decision is said to be the final hurdle for the sale of E15 blends.

In passing the regulations, the EPA ignored the warnings of experts, including the auto industry, which has warned that many owners of older cars – more than three years old – could easily damage their engines by using the spiked ethanol blend. 

 DANGER WILL ROBINSON

If your car is over 4 years old...

 

 Read the 179 page pdf  HERE

The EPA also ignored the most environmentally conscious drivers on the planet, those in Europe where the option to use E10 blends has fallen flat.  In Germany, all petrol companies began offering E10 blends as an option at service stations at the beginning of this year.  Six months later, sales of E10 continue to meet strong resistance from German car owners, who have avoided using the blend because of fears that it could damage their cars’ engines. 

Commenting on the regulation, Gloria Berguist, a spokesperson for the Alliance of Automobile Manufacturers, an industry trade group, stated,”We see the final rule fails to require that service station pumps contain a warning label directing consumers to check their owner’s manual to determine the appropriate fuel for specific vehicles.  This is a significant and unfortunate omission.”

But perhaps Sheila Karpf, legislative and policy analyst at the Environmental Working Group, a nonprofit research group, said it best.  “A label can only do so much to protect consumers from the hazards of misfueling with E15 and won’t prevent a wave of voided vehicle warranties when vehicles are misfueled.  It’s unfortunate that the Obama administration, in a rush to placate the corn ethanol lobby, is going to hurt consumers and ultimately taxpayers, who will be forced to address the damage done by our misguided ethanol policy.” 

(SOP: Or, as I learned in my business ethics class: “What’s the object of the act?”)

Indeed, next time you fill up, check the number of labels that are already on a gasoline pump.  When was the last time you read what they all say?

Growth Energy, a trade group that represents ethanol producers, predicted E15 will be at your local service station by the end of the year. 

Story Courtesy of Automotive Newswire

Photo credit


Washington Action: Clarifying EPA’s Proposed “Clarification” of the Article Exemption

July 27, 2010

Three points you should know about the EPA’s proposed TRI ‘Clarification’

  1. It underestimates industry burden. It would cost our Precision Machining Industry on the order of $3,534,104 in preparation,  collection of data, analysis and reporting costs.
  2. This impact falls mainly on our small businesses – 54 % of US Precision Machining shops employ less than 20 employees.
  3. The “Clarification” does not provide a positive impact on public health and safety, and it wil llikely foster over reporting, double counting of “releases” and otherwise mislead the public.

We recently attended a meeting with the Office of Management and Budget (OMB) and Environmental Protection Agency (EPA) officials regarding EPA’s proposed “Clarification” of the Article exemption under TRI 313 Reporting. We were joined with representatives of roughly 14 other industry spokespeople at this meeting. 

Read our submission to OMB and EPA.

Many precision machining shops make use of the article exemption in some form, so any changes to the definition would require all  precision manufacturing companies to reassess  their need to report under the new clarification. In the US, that means 3,364 perecision machining establishments would need to spend, according to the EPA’s own estimates, 51.3 manhours to properly evaluate and report.

While the EPA’s federal register comments indicate that only the treated lumber industry would be affected,  representatives from a wide range of  industries were in attendance to show how the proposal would eliminate the Article Exemption for their products.

PMPA was there to show how, if the Article Exemption were lost, the reporting burden  for our industry would be orders of magnitude higher than the EPA’s estimate of $13,877.

$13,877!

That’s right. EPA thought that the TOTAL INDUSTRY Reporting Burden for this “Clarification’ would be no more than $13,877.

Using the 2007 Survey of Manufactures data from the U.S.Census, We were able to show that the cost of evaluating our new reporting status as an industry would be at least $3,534,104. That is just for Precision Machining Shops.

For Fabricated Metals, which includes Precision Machining, the burden jumps to $66,235, 899. And for the entire 33 NAICS code, including Precision Machining, Fabricated Metals, and Machinery Manufacture, the impact is over $209 Million Dollars.

EPA’s estimate of Reporting burden for NAICS 33XXXX underestimates by a multiple factor of 15108.83 times.

PMPA’s mission and vision charges us to provide resources that  “advance and sustain”  member companies within the Precision Machining Industry.

That’s why we went to Washington. To save you and 3,363 of your peers from a “clarification” that would have burdened the industry to the the tune of about $3,534,104.  Or US manufacturers in NAICS 33 about $209 million.

 EPA would better serve its mission by clearly defining what is a release, and exempting legitimately recycled materials such as scrap metals from TRI reporting.

That’s is a change we could support.

Read our submission to OMB and EPA.

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