>>> Fern Abrams <[log in to unmask]> 07/03/01 08:49AM >>>
IPC Files Comments Opposing EPA's Proposed Wastewater Effluent Limitation
Guidelines


IPC filed comments yesterday opposing EPA's Proposed Metal Products and
Machinery (MP&M) effluent limitation guidelines (ELGs).  IPC's comments,
over 300 pages in length, offer detailed comment on EPA's failure to
properly evaluate its proposed rule in relation to the PWB industry.  This
lack of analysis by EPA resulted in a proposal that overestimates
environmental benefits while significantly underestimating the costs and
economic impacts upon the PWB industry.

According to Fern Abrams, IPC Director of Environmental Policy, "This
proposal is a classic example of bad government regulation.  It was poorly
researched and based upon a host of unjustified assumptions and improper
extrapolations."

On behalf of its members, IPC requested that EPA assess realistic PWB
wastewater treatment capabilities, obtain a true estimate of the pollution
expected to be removed by a proposed rule, obtain a more realistic estimate
of the cost of compliance, and correct the economic impact analysis.  As a
part of this effort, IPC expects EPA will visit and collect wastewater
samples at several PWB facilities.  Data gathered during these site visits
will be published in a notice of data availability (NODA) early next year.

The proposed MP&M effluent guidelines regulate pollutants content in PWB
facility wastewaters discharges.  The proposed guidelines are extremely
stringent and will require extensive and costly process modifications in
most PWB facilities.

EPA has estimated the total annualized cost (in 1996 dollars) of the MP&M
rule to be $147.1 million for the PWB industry or slightly over $250,000 per
facility.  EPA calculates that 7 PWB facilities will be forced to close due
to the costs of complying with the MP&M guidelines.  An additional 301
facilities are expected to have difficulty financing compliance investments
or on-going business investments as a result of the rule.

For the full text of IPC's comments, visit our web page at 
http://www.ipc.org/html/fslegislative.htm  (this is the corrected link)

Fern Abrams
Director of Environmental Policy
IPC - The Association Connecting Electronic Industries
1400 Eye Street NW, Suite 540
Washington, DC  20005
202-638-6219
fax 202-638-0145