Recent industry-user-financed studies predicting major job losses in plants if the U.S. Environmental Protection Agency’s (U.S. EPA’s) Industrial/Commercial/Institutional (ICI) Boiler Maximum Achievable Control Technology (MACT) standards go into effect as originally proposed “are flawed,” Randy Rawson, president of the American Boiler Manufacturers Association (ABMA), said. Rawson released a statement after it was divulged that the U.S. Department of Commerce (U.S. DOC) has weighed in with a so-far-unreleased opinion on the economic impact of the U.S. EPA’s proposals.

“If indeed such a study exists, the U.S. DOC analysis must be made public; those affected by the EPA proposals—both positively and negatively—are owed the chance to be able to determine just how the department came up with its conclusions, whether its methodology can withstand scrutiny, and to what degree it analyzed job-creation potentials related to this standards-setting process. That can’t happen until the U.S. DOC study is made public.

“More importantly, not one of the studies we’ve seen so far makes even a minimal attempt to calculate or to take into consideration the number of offsetting, solid manufacturing jobs in the boiler industry that will be created as a result of EPA promulgating sensible and achievable standards. Because they ignore this potential, all these job-loss studies are unavoidably flawed.

“I want all those Congressman and Senators who have railed against these proposed boiler standards to look around themselves to see just how many jobs in their congressional districts and states are linked to the boiler and boiler-related equipment-manufacturing industry—the boilers; the combustion equipment; the ancillary products, like valves, gages, traps, tubing, and other boiler-related items; the emissions controls equipment and products—and all those small businesses engaged in boiler sales, repair, installation, and in the aftermarket-services sectors that are likely to be affected by this process. And I want those Congressmen and Senators to tell those small businesses, their employees, and all their prospective employees—professional, skilled, and unskilled—that might find work because of [National Emissions Standards for Hazardous Air Pollutants (NESHAP)] boiler standards why they are trying to derail these standards before they even know what they are.

“ABMA did not entirely support the standards as originally proposed, and we have made every attempt to counsel EPA on how they could be made more achievable and less onerous. EPA Administrator (Lisa P.) Jackson has already declared that ‘the final standards will most assuredly differ from the proposed ones,’ so any studies of the original versions can only be considered as ploys to spawn antipathy toward something that may not even exist in final form.

“If the final standards are uninformed or defy technical realities, this industry will be the first to step forward in opposition, as we did with the original proposals; but, until that becomes the case, this standards-setting process provides a substantial opportunity to those desperately in need of well-paying, manufacturing jobs in localities in virtually every section of this country, and we don’t believe their aspirations deserve to be forgotten or minimized in a rush to find fault in an outcome that hasn’t even been finalized.”

Complete comments filed with the U.S. EPA by the ABMA on NESHAP can be found online.