Where environmental standards and regulations are concerned, manufacturers have a critical need for the following:
- Clarity, predictability and consistency
- Policies that reflect scientific consensus
- Commonsense enforcement
- Careful cost-benefit analysis as part of the policymaking process
Manufacturers also urge policymakers to exercise restraint in establishing state environmental standards and regulations that exceed federal standards and regulations, and to avoid doing so altogether without clear and convincing evidence that more stringent standards or regulations are necessary. At the same time, manufacturers understand that fair and reasonable regulations must be balanced with responsible stewardship of our natural resources.
Industry leads the way in solid waste reduction and recycling. Reduction and recycling include source reduction activities, reuse, recycling, composting and incineration. Industry is an enormous consumer of recycled materials, such as metals, glass, paper and plastics; manufacturers thus are strong advocates for improving recycling systems in Ohio and the nation.
Environmental policy priorities include the following:
- Expand the focus of Ohio’s state implementation plan for attaining National Ambient Air Quality Standards (NAAQS) and for reducing releases of substances regulated by EPA to the environment (air, water and land) beyond industrial sources to also include controls for non-industrial and mobile sources of releases.
- Revise existing statute to allow companies to appeal Ohio EPA Notices of Violation (NOVs) to Ohio’s Environmental Review and Appeal Commission.
- Require Ohio EPA to evaluate and use best practices for implementation of federal environmental regulations to avoid putting Ohio manufacturers at a competitive disadvantage because they face greater regulatory burdens than competitors from other states do based on Ohio EPA’s stricter interpretation of federal regulations.
- Give companies whose environmental permits are appealed by third parties the option, for a fee, of a “fast track” process and expedited resolution of the appeal, which otherwise can discourage investors because Ohio’s appeals process can go on for years.
- Expand opportunities for industry to reuse non-harmful waste streams. Beneficial reuse policies can result in less waste and more recycling of industrial byproducts.
- Review Ohio’s solid waste regulations, including procedures for disposing universal waste streams, to ensure safe and uniform disposal practices that are consistent with best practices used in other states.
- Reject state-level efforts to implement product composition mandates. Such standards and requirements are best addressed at the federal level rather than through a patchwork of differing state-level requirements.
- Reject extended producer responsibility policies that would shift responsibility for recycling certain consumer products from consumers to manufacturers.