>>> 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