The Ohio Manufacturers’ Association (OMA) is urging Ohio Environmental Protection Agency (EPA) to preserve flexibility in proposed nutrient rules that could impose major costs without delivering meaningful water-quality gains.

In comments submitted this week, OMA generally supported Ohio EPA’s scientifically based approach to nutrient regulation but warned that several provisions could expose manufacturers to unnecessary capital investments, operating costs and even operational disruptions. OMA is asking the agency to expand the use of adaptive management and avoid rigid, one-size-fits-all phosphorus limits when site-specific solutions could produce better results.

“Good environmental policy should solve an actual environmental problem,” said James Lee, managing director of public policy services at OMA. “If a facility contributes very little to a nutrient impairment, forcing it to spend enormous amounts of money on treatment that produces little measurable improvement is neither sound policy nor sound science. We’re asking Ohio EPA to preserve the flexibility to match the solution to the problem.”

OMA also urged Ohio EPA to use actual discharge flows rather than facility design capacity when determining which industrial facilities are covered and to provide additional flexibility for small dischargers whose nutrient loads are not driving water-quality impairment.

The association further recommended allowing load-based limits and other tailored approaches as alternatives to bright-line concentration limits, particularly when costly infrastructure upgrades would provide little environmental benefit. 8/24/2026