News and Analysis
This week Senator John Eklund (R-Chardon) provided sponsor testimony for Senate Bill 228, legislation which would increase the state fees on solid waste, doubling the municipal solid waste fee from $0.25 per ton to $0.50 per ton.
The fee increase would be used to fund the Soil and Water Conservation Districts (SWCDs) in each county. SWCDs are independent political subdivisions of state government organized along county boundaries to provide technical assistance to urban and rural land users. An elected board of local citizens provides SWCD leadership. Local offices provide education and programs. Most programs are designed for agricultural and nonpoint sources. Therefore, this bill appears to be a fee increase for almost no new benefit for manufacturers.
There was an attempt to include this proposal in the last state budget and the OMA will again be working to make sure it does not get into the next state budget. 12/6/2018
Each year Ohio EPA recognizes organizations in the Buckeye State for exceptional achievements in environmental stewardship through the Ohio EPA’s Encouraging Environmental Excellence (E3) Program.
Maybe this is the year for your business to be recognized for your commitment to environmental excellence?
The application deadline for the 2019 awards is December 14, 2018.
This week Ohio EPA proposed amendments to three Implementation of Water Quality Standards (Modeling) Program Rules in Ohio Administrative Code Chapter 3745-2:
- 3745-2-04: Determinations preliminary to development of water quality-based effluent limitations
- 3745-2-10: Waste load allocation for ammonia-nitrogen toxicity
- 3745-2-12: Total maximum daily loads
These rules are being proposed in order to comply with the five-year rule review requirement and to incorporate revisions consistent with new requirements for Total Maximum Daily Load (TMDL) limits passed in last year’s state budget bill.
That bill specifically requires the agency to adopt rules that establish procedures for providing notice to stakeholders and criteria for determining significant public interest in TMDL development.
OMA is on the record (see comment 17) regarding these proposals to ensure that manufacturers and their trade associations can request public hearings on any new TMDLs. 11/13/2018
The Ohio EPA’s webinar regarding Nutrient Water Quality Standards for Ohio’s Large Rivers Early Stakeholder Outreach is online; you can watch the recording here. 11/15/2018
Ohio EPA has multiple stakeholder opportunities with deadlines hitting over the next month. Let OMA’s Rob Brundrett know if you have any questions or would like to comment.
- November 13, 2018, Division of Air Pollution Control (DAPC), comments due and public hearing, Architectural and Industrial Maintenance (AIM) Coatings Rules.
- November 14, 2018, Division of Air Pollution Control (DAPC), comments due and public hearing, Ambient Air Quality Standards.
- November 19, 2018, Division of Environmental and Financial. Assistance (DEFA), comments due and public meeting, 2019 Water Pollution Control Loan Fund (WPCLF) Program Management Plan.
- December 3, 2018, Division of Surface Water (DSW), comments due and public hearing, Pretreatment and Indirect Discharge Permit Rules.
- December 5, 2018, Division of Surface Water (DSW), comments due and public hearing, Storm Water Program and General NPDES Permits (OAC Chapters 3745-38 and 3745-39).
Last week the OMA submitted supportive comments to the U.S. EPA on the proposed update to the NOx state implementation plan (SIP) Call regulation.
This proposed rule would amend the existing NOx SIP Call regulations to allow states to revise their SIPs to replace the current requirements for certain sources to monitor emissions with alternate monitoring requirements. The proposal would also eliminate obsolete provisions and make non-substantive clarifications to the remaining regulations.
In its comments OMA wrote, “The proposal would allow alternative monitoring to costly Part 75 CEMS while still providing the necessary assurance that covered units are achieving the required emission reductions under the NOx SIP Call.”
Ohio EPA also submitted comments supporting the proposed federal rule. 10/29/2018
This would be a new rule intended to contain Ohio’s standards for eutrophication endpoints in Ohio’s Large River Assessment Units. Large rivers are those that drain over 500 mi2.
This new proposed rule would establish nutrient standards for these large rivers. In addition, a target phosphorus concentration is being considered for river segments that are over-enriched as demonstrated by the standard.
OMA’s comments dove into the technical aspects of the proposal and questioned portions of the ESO. OMA requested that Ohio EPA convene a stakeholder group to provide interested-party feedback, expert support, and industry analysis as part of the rulemaking process for this important nutrient rule.
OMA also submitted more general comments in conjunction with the Ohio AgriBusiness Association.
Thank you to the member companies which submitted comments on this issue. And thank you to the OMA nutrient working group members for your help and feedback with the comments.
Earlier this week, Ohio EPA announced via public notice a final rule for hazardous waste wipes and apparel exclusions. The final rule concerns an Ohio-specific rule to conditionally exclude contaminated wipes and apparel (that are not currently excluded under the solvent wipe rule) from regulation under the hazardous waste regulations when certain conditions are met.
The apparel would include, but not be limited to, gloves, uniforms, smocks, and coveralls that are laundered and intended for reuse.
OMA sent in several sets of comments during the rulemaking process including this final set of comments submitted in July. The EPA improved the rule from its initial draft, but the rule is still more complicated than it need be.10/29/2018
The Ohio EPA’s Encouraging Environmental Excellence (E3) Achievement Award recognizes organizations for their environmentally beneficial activities.
The Achievement Award is open to any Ohio business or organization, and awards are given at silver, gold and platinum levels.
Applications for 2019 awards are due by December 14.
Bet you have something to submit! More here. 10/17/2018
To help OMA members network, learn and share about sustainability goals, practices and projects, the OMA created the Sustainability Peer Network.
The next event, co-hosted by the Whirlpool Corporation and One Energy in Findlay, is Friday, October 26.
Whirlpool’s energy, water, waste and other sustainability initiatives will be showcased.
There will be a tour of the North Findlay Wind Campus, which jointly serves Whirlpool Corp. and Ball Corp. manufacturing facilities.