FPA responded to the Department of Commerce on the White House Memorandum Requesting Information on Domestic Manufacturing Burdens (see 82 Fed. Reg. 12,786, Mar. 7, 2017). In the comprehensive comments submitted on March 31, 2017, FPA identified several permitting, compliance, and/or operational requirements that negatively influence the construction, expansion, innovation, and competitiveness of domestic manufacturing.

In each case, FPA made specific recommendations to address the concerns. FPA argued that of the five types of environmental permits required to build, expand, and/or operate a manufacturing facility, the preconstruction permitting and prohibitions on construction before the 7-12 month period needed for obtaining the new source review permits affected the timely expansion of the industry, causing a competitive disadvantage in the global economy.

Additionally, the impact of overlapping Federal and State permit programs is readily apparent under the Clean Air Act. Specifically, FPA recommended that the Department of Commerce evaluate and redefine the roles of the Federal and State governments in regards to the permitting process to avoid overlapping burdens and risks to manufacturers. Mandating shortened periods and checklists for the issuance of air and water permits is in order.

For More Information

A copy of the full set of issues and recommendations can be obtained from Ram Singhal at rsinghal@flexpack.org or 410-694-0800.