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 jhannapel@thepolicygroup.com.
