1737 King Street  Suite 390  Alexandria,VA 22314  tel 571.970.3400  fx 571.970.3271 Comments from Allen Blakey Vice President, Industry & Govt. Affairs

The Vinyl Institute To the U.S. Environmental Protection Agency
Re: National Emission Standards for Hazardous Air Pollutants For Polyvinyl Chloride (PVC) and Copolymers Production

June 7 & 9, 2011

On behalf of the Vinyl Institute, I appreciate the opportunity to speak at today’s hearing on EPA’s proposed Maximum Achievable Control Technology regulations for PVC production facilities. As you heard earlier, the Vinyl Institute is the tr ade association for manufacturers of polyvinyl chloride resin and copolymers in the United States.

I am speaking today not to address technical issues in the proposed regulation but to underscore the value of vinyl to the national economy, as
well as this industry’s commitment to protecting the health of our workers, plant communities and the environment. Our stewardship commitment is altogether fitting given the nature and purpose of so many critically important PVC products. Vinyl is the material of ch oice for blood bags and medical tubing, for pipe delivering clean, safe drinking water, and for insulation on building wire protecting against catastrophic electrical failure. It is the material of choice for food wrap and tamper

- resistant packaging. It
is the material of choice for home

- owners interested in the most affordable and energy

- efficient window frames and commercial roofing. And the list

goes on.

The PVC resin manufacturing industry supports this MACT rule

- making.
T he industry has long

- opera ted under the vinyl chloride standard, a1737 King Street  Suite 390  Alexandria,VA 22314  tel 571.970.3400  fx 571.970.3271 precedent

- setting rule in both its scope and stringency. To support the current rule making, the industry has expended significant man

- hours and millions of dollars to generate the information EPA needed to develop the proposed rule. We know that the agency is working hard, under a very short deadline, to finalize this regulation. We intend to bring our best thinking to the comments we will file in order to help develop the most effective, manageable rule that is f ully compliant with the Clean Air Act and related precedents.

I’d like to share some facts with you that I think clearly show this industry’s success in practicing environmental stewardship, conserving energy and reaching for sustainability.

 Our vinyl chl oride emissions were reduced 80% between the years
1987

- 2007

.

 Our dioxin emissions were reduced 80% simply between 2000

- 2007.
Our emissions are a small fraction of the emissions from all man

- made and natural sources. And, by the way, data compiled by E PA shows that overall dioxin emissions to the environment have plummeted since the 1960s, falling well over 90%, even as production and use of vinyl ramped up and soared.

 The collection of federal U.S. regulations governing the industry sets global standar ds for human and environmental safety, health and performance.

Manufacturing plants also have community advisory boards that meet regularly with management for dialogue on operations and community
issues. These plants strive to be good neighbors. After all, they draw their employees from the community, and provide jobs and taxes.

And, the evidence shows that our plants are by and large good neighbors, managed responsibly in accordance with regulations designed to protect
health. Government studies at both the federal and state levels have compared key health indicators in PVC plant communities and non

- plant communities and found no significant differences.1737 King Street  Suite 390  Alexandria,VA 22314  tel 571.970.3400  fx 571.970.3271 We are concerned that EPA get this rule right. Regulation is important and necessary, but as C ongress intended for the Clean Air Act, other considerations matter too. We all want a clean, healthy environment, but we also want products that bring value to our lives, and we want jobs and a strong economy. How does the PVC industry help?

 Our industr y generates an estimated $50 billion a year in products. Federal taxes from producing the raw material alone amount to $230

million.

 The 13 billion or so pounds of PVC manufactured in 2010 created high

paying jobs for tens of thousands of American manufac turing workers, and many times more jobs for transporters, distributors, installers, and recyclers. Vinyl products are made in hundreds of plants in almost every state.

 U.S.

- made vinyl resin is in high demand as an export product, accounting for as much as 35% or more of industry revenues. Abundant natural resources and an efficient manufacturing process
account for this success

We look forward to providing additional details in our written comments. Thank you.