- According to the U.S. DOE, not only does the U.S. steel industry lead the global steel sector in energy efficiency, it generates the second lowest amount of CO2 emissions per ton of steel produced anywhere on the planet, behind only South Korea.
- Steel is the most recycled material in North America. Ohio steel makers advocate continuous improvement in environmental performance the participation with government and community groups in creating responsible laws, regulations and standards to safeguard the community and the environment. We support clarity, predictability and consistency in regulations; policies that reflect scientific consensus; commonsense enforcement; and careful cost-benefit analysis as part of the policymaking process.
- Public policy can be a major asset — or a major liability — for companies and states seeking to build competitive advantage. While certain improvements have been made to Ohio’s air permitting process within the last five years, a number of other anti-competitive environmental policies and practices need to be addressed.
- Air quality standards have a major impact on our business. There are a number of potentially useful actions that could be taken to mitigate the threat of more rigorous air quality standards:
- The Governor’s Office and Ohio’s congressional delegation should join the Ohio EPA in voicing strong opposition to further reductions in the allowable levels of ozone emissions.
- Ohio needs enhanced data analysis, modeling tools and technical assistance that would allow for more comprehensive evaluation of the potential impact of proposed new federal air-quality standards. Such resources are needed to provide stronger advocacy for Ohio industry and a more robust consideration of options for achieving more rigorous emission standards with minimal impact on the manufacturers and other regulated employers that generate investment, create jobs and stimulate economic activity in our state.
- When Ohio EPA has formulated previous state plans for achieving attainment of air quality standards, historically the focus has been on controlling the large stationary sources of ozone emissions — i.e., the power plants, the steel mills and other large manufacturing industries. But, the reality is that non-industrial sources and mobile sources — cars, trucks and heavy equipment — are large sources of ozone. If more stringent standards for ozone emissions are approved, Ohio EPA should establish expanded controls for non-industrial sources, which will yield greater benefit and have less of a negative impact on Ohio’s economic competitiveness.
- The Ohio General Assembly should revise existing statute to allow companies to appeal violations to Ohio’s Environmental Review and Appeal Commission (ERAC).
- Ohio EPA should refrain from issuing a violation until the involved parties have exhausted all non-public options/solutions, such as permit modifications in situations where the alleged “violation” is simply a matter of paperwork and no environmental damage has occurred.
- As Ohio manufacturers continue retooling their operations for maximum global competitiveness, state lawmakers and regulators should exercise restraint in establishing state standards and regulations that exceed federal standards and regulations, and should avoid doing so altogether without clear and convincing evidence that more stringent standards are necessary.
- To help ensure a level playing field for Ohio companies competing in national and global markets, Ohio EPA should be required to evaluate and use best practices for implementation of federal regulations.
- Ohio EPA’s enforcement of environmental regulations and rules must reflect a careful balance of environmental protection goals, cost-benefit analysis and sound science.