PMA Pushes Back on Excessive EPA PM2.5 Rulemaking

PMA supports American manufacturers by participating in EPA hearing on excessive PM2.5 (particulate matter) rulemaking.  

Testimony of: 

Carl A. Marrara
Executive Director
Pennsylvania Manufacturers’ Association

February 23, 2023
Public Hearing Before the EPA

Good afternoon. I am Carl Marrara, the Executive Director of the Pennsylvania Manufacturers Association. Founded in 1909, the Pennsylvania Manufacturers’ Association is the nonprofit, statewide trade organization representing the manufacturing sector in Pennsylvania’s public policy process. 

We appreciate the opportunity to address the EPA at this public hearing. The public relies on reasonable regulations to set clear rules that support a clean environment, safe workplaces, and a better quality of life. Closed-door negotiations, partisan rulemaking, and lopsided bureaucratic decisions only lead to confusion. 

As the leading voice for manufacturing in our commonwealth, we join manufacturers across the U.S. in strong opposition to EPA’s PM2.5 rule proposal that would impose stricter air standards on U.S. businesses. American families are already concerned about the threat of a recession. Imposing new, burdensome regulations on the businesses they rely on will only further weaken an already slowing economy. Manufacturing is the engine that drives our economy here in Pennsylvania and across the United States; adding the most value and sustaining tens of millions of jobs on our shop floors and in related industries.  

American manufacturing is at a crossroads. The same manufacturers that changed their lines to supply PPE, medical devices, and safety equipment are now finding their stride in response to challenges with excessive inflation and a looming recession.  Additional unrealistic regulations will inhibit our sector from fully bouncing back, leading to more of our jobs and our products being produced overseas. This unnecessary offshoring would be detrimental to our economy and our environment.

Manufacturing in the U.S. is cleaner and more sustainable than ever thanks in large part to a revolution in how we produce, use and recycle energy – a transformation that has been spearheaded by innovative manufacturers. Across the board, levels of major pollutants have declined dramatically, and the U.S. is outpacing global competitors. According to the EPA, the U.S. has reduced six common NAAQS pollutants (including PM2.5) by 78% between 1970 and 2020. And EPA affirms that PM2.5 levels have dropped 44% since 2000.

The U.S. already has some of the strongest environmental performance standards in the world, yet there are still areas of the U.S. that are in nonattainment under the current PM2.5 standards. Issuing stricter standards will leave behind areas currently in nonattainment and will make permitting significantly harder for manufacturers. New manufacturing here in the United States is cleaner, more efficient, and stabilizes our fragile domestic supply chains. But with unattainable standards as law, we will miss out on the economic and environmental benefits our domestic manufacturers fulfil. 

Let’s not incentivize manufacturing in China, India, the Philippines, or other locations that do not have the same air quality standards and practices that we have here, domestically. Study after study shows that the excessive pollution that occurs in these foreign locations gets pushed via the jet-stream to the United States, particularly to the Pacific Northwest. These background levels then become a part of what is measured for attainment, yet our domestic manufacturing sector has no control over foreign pollution generation and migration. 

America’s manufacturers are a part of the solution, not the problem. Let manufacturers do what they do best: innovate and develop modern technologies that address air quality, reduce emissions, and protect the environment, while investing in the manufacturing workforce and growing the economy. Constantly moving standards and additional permitting challenges are counterproductive. On behalf of Pennsylvania’s manufacturers, we strongly urge EPA to reconsider its proposal and we thank the EPA for the opportunity to speak today.