July 2020 MiMfg Magazine 9
Leading Challenges on
Environmental Regulations
By Dave Greco, III • MMA
Environmental regulatory challenges continue to
burden employers as significant new issues rise up to
threaten Michigan’s ability to retain its existing
manufacturing jobs, exacerbating an already difficult
business climate due to the continued uncertainties
of COVID-19.
Without the constant and vigilant intervention
of the MMA, seemingly mundane regulatory
initiatives within the Michigan’s Department of
Environment, Great Lakes, and Energy (EGLE)
that are in fact costly and unworkable threats to
industrial operations, could slip through unchecked.
Impact of Air Pollutants from
Out-of-State Sources
MMA is working to block increasingly ineffective
regulations that pose little or no benefit to Michigan’s
air quality so long as the state remains significantly
impacted by out-of-state emission sources. In spite
of Michigan manufacturing’s own best efforts, new
cost burdens could be imposed through Federal Clean
Air Act regulations both statewide and in the state’s
ten ozone nonattainment areas. By 2021, a bump up
in Michigan’s nonattainment designation could
further increase costs and potentially limit growth.
In 2019, MMA led a regional delegation of
manufacturing organizations to discuss the impact
of international emissions and viable regulatory solutions
with the U.S. Environmental Protection Agency (EPA)
Region V administration. On 6/2/20, MMA joined
EPA Administrator Andrew Wheeler, Region V
Administrator Kurt Thiede and U.S. Congressman
Fred Upton (MI-06) to announce remarkable improvements
in national air quality. MMA remains vigilant in
protecting manufacturers’ economic competitiveness.
Pursuing a Rational and Science-
Based Approach to PFAS
As attention on PFAS and related compounds
remains high, the Whitmer Administration seeks to
establish some of the nation’s most strict drinking
water standards. Moving hastily, the State has failed
to account for the costs, disregarded a robust peer
review process driven by the MMA and stretched
the bounds of settled science.
The unbalanced regulatory costs imposed on
manufacturing will be substantial. Most concerning is
the State’s acknowledgement that it cannot fully account
for the cost but will continue to move forward anyway.
Stay Informed
Regulations constantly shift and uninformed manufacturers
are at risk of increased costs and unintended compliance
violations. Get the latest updates by joining an MMA
Policy Committee or subscribe to MMA’s weekly MFG
Voice e-newsletter. See mimfg.org to learn more.
MMA has been the leading business advocate on
the proposed PFAS rules since their 2019 introduction
and has worked to ensure our recommendations and
independent, technical review are fully considered and
addressed by the state’s Joint Committee on
Administrative Rules (JCAR), the legislative body
responsible for oversight of administrative rules.
On 6/3/20, JCAR underscored the importance
of MMA’s role in a letter to EGLE where the
Committee requested further clarification and
answers in line with MMA’s noted concerns. The
letter stated that “public comments such as those
from the [MMA] included an independent, peer
review from scientific experts that had numerous
scientific and technical questions that appear to not
be addressed by the Science Advisory Workgroup
or EGLE as part of its final package.”
Draft Chloride & Sulfate Water Quality
Criteria Implementation Plan
The Association remains concerned about the
workability of EGLE’s Draft Chloride & Sulfate
Water Quality Criteria Implementation Plan, and is
working to ensure a transparent and fair process for
vetting the proposal. MMA is engaged with officials
to urge the consideration of questions raised by
manufacturers before advancing too far into
implementing new criteria.
Michigan manufacturers must continue to work
productively with state regulators to ensure credible
regulations to protect the state’s environment and
maintain economic competitiveness. Only by staying
vigilant and actively working to influence the development
of impactful and costly rules can manufacturers be assured
that a balanced approach to both economic competitiveness
and environmental stewardship is possible. 6
Dave Greco, III is MMA’s Director of Regulatory &
Environmental Affairs. He may be reached at
517-487-8543 or [email protected].