When the Strategic Goals Program (SGP) was created, I was fairly impressed with the idea. Basically, the program was designed to provide finishers incentives, such as reduced compliance costs, for voluntarily going further than environmental regulations required. The program was to be the model for performance-based stewardship by industry as opposed to the command-and-control philosophy EPA was operating under. In fact, EPA's Web site states that the finishing industry has gone further than any other industry to date to promote the "cleaner, cheaper, smarter" philosophy.
While EPA has highly touted the program in the finishing industry, I am a little confused and uncertain about the status and success of SGP. Why? Do the letters MP&M mean anything to you?
If you haven't heard by now, MP&M is the Metal Products and Machinery Rule. The proposed regulation was expected to be formally issued in the Federal Register in December by EPA.
According to Government Relations, the proposed regulation sets limits for metals in wastewater discharges that are approximately 50-80% lower than existing standards. The federal government estimates that the cost to comply with this regulation will be $150,000 per facility. However, Government Relations believes the cost will be closer to $500,000 per facility.
So, if MP&M becomes law, will it render SGP moot? I thought SGP was supposed to somewhat relieve the finishing industry of future burdensome regulations due to its good faith effort, but it seems that MP&M would trump SGP.
Will finishers now have to go beyond the regulations in MP&M to receive any incentives under SGP? That could be a pretty difficult level for many finishers to reach.
Does the possibility of MP&M and the mandatory lower levels in that regulation mean that EPA has gone back to the command-and-control philosophy? This certainly won't encourage finishers to voluntarily go beyond the regulations.
I have many other questions about MP&M as well. I'm sure you do too. If so, take this as a reminder to voice your opinion. The comment period will last for another 90 days. If you have something to say regarding MP&M, contact Government Relations at 202-965-5190 or email@example.com.