MMA ’ s Manufacturing Agenda 13
Policy principles to support a competitive manufacturing sector . Michigan must :
■ Stop efforts to adopt local environmental ordinances that create a complicated patchwork of regulations adding to bureaucratic complexity of the state and negatively impacting the state ’ s business climate .
■ Ensure Michigan ’ s environmental rules and regulations do not exceed federal standards without clear and convincing need to exceed the applicable federal standards .
■ Ensure federally mandated program fees fund only the federally mandated programs .
■ Reduce or eliminate environmental program fees which reduce manufacturers ’ ability to compete globally while recognizing that a healthy environment and competitive economy are not mutually exclusive goals .
■ Develop efficient , timely and responsive permitting programs in the Department of Environment , Great Lakes , and Energy .
■ Establish environmental standards based on settled science to encourage environmental cleanups and competitive permitting .
Specific Actions for Leaders :
■ Preserve General Fund State Appropriation for Title V Air Fee program .
■ Support efforts to limit federal EPA air non-attainment areas in the state and develop a strategy with stakeholders and state regulators to implement proper , defensible standards .
■ Develop a comprehensive update to Michigan ’ s Environmental Remediation Statute — namely updates to groundwater , soil , and vapor intrusion provisions – with the regulated community and EGLE to ensure proper cleanup standards are in place and state regulators follow and utilize statutory provisions to encourage more cleanups .
■ Support processes for limiting new administrative rules that exceed federal standards , unless it is determined there is a clear and convincing need .
■ Provide oversight and ensure that state regulators properly using the Administrative Procedures Act for rule promulgation rather than developing guidance or other internal policy documents .
■ Support legislative efforts to improve the Environmental Rules Review Committee by establishing a Science Advisory Subcommittee .
■ Protect manufacturers from unnecessary and frivolous legal challenges to permits and consent orders .
■ Develop an efficient , effective update for Michigan ’ s hazardous waste program .
■ Support a rational and science-based strategy to handle emerging contaminants that properly account for the risk and associated costs with any new rules or regulations .
■ Focus a recycling strategy on market development for recycled products .
■ Support legislative efforts to update our State ’ s nearly two-decade old solid waste statutes to sustainably manage materials in a way that benefits the economy , communities , and the environment .
■ Support legislative efforts to improve the rules process through changes to the Administrative Procedures Act that ensures continued oversight over the rule promulgation process .
■ Guard against efforts to implement anti-competitive and discriminatory regulations on manufacturers .
■ Protect and expand beneficial reuse criteria to reduce waste and increase productive use of materials .
Caroline Liethen MMA Director of Environmental and Regulatory Policy liethen @ mimfg . org 517-487-8543 mimfg . org