1737	King	Street,	Suite	390, Alexandria,	VA		22314		( 571)	970

- 3359 Fax	(571)	970

- 3271 www.vinylinfo.org www.vinylindesign.com Page 1 of 2 

# Vinyl	Institute	Key	Issues	With	Proposed	PVC	MACT	Standard
December	29,	2011



##  As	proposed,	the	PVC	MACT	rule	has	calculation	errors	and	cannot	be	met	by the	industry.

 Inappropriate	statistical	factors	were	used	by	EPA	that	do	not	correlate	with	the	complia nce measurement	period.		The	best	performer	will	automatically	be	in	violation	1	of	every	100 days.		Appropriate	factors	and	calculation	methods	must	be	applied	to	industry’s	best available	databases	to	determine	emissions	limits	that	consider	variability and	provide flexibility	for	over	one	hundred	grades	of	resin	needed	to	meet	our	customers’	expectations for	quality	products.



##  As	proposed,	U.S.	plants	will	be	closed,	thousands	of	jobs	will	be	lost,	and significant	volumes	of	exports	will	be	eliminated	and replaced	by	imports produced	by	foreign	suppliers	that	do	not	meet	U.S.	emissions	limits.

 Calculation	errors	will	result	in	the	shutdown	of	significant	segments	of	the	resins manufacturing	industry	in	the	U.S.	where	no	known	technology	exists	to	meet	EPA ’s proposed	limits.		New	source	limits	are	based	solely	on	a	small	snapshot	of	our	industry’s operations,	and	do	not	provide	the	needed	variability	to	build	new	facilities	to	meet	PVC resin	demand	that	is	growing	over	3%	annually	on	a	global	basis.		Export s	will	be	constrained and	U.S.	manufacturing	will	falter	without	flexibility	being	built	into	the	final	rule.



##  As	proposed,	the	economic	impact	qualifies	this	as	a	major	rule.		Direct ongoing	annual	costs	for	PVC	resin	producers	and	processors	will	be	$130 million,	direct	initial	costs	as	a	result	of	compliance	for	PVC	resin	producers and	processors	will	be	$200	million,	and	the	broader	economic	impact	on	the U.S.	economy	will	amount	to	billions	of	dollars	and	thousands	of	American jobs	lost.1737	King	Street,	Suite	390, Alexandria,	VA		22314		( 571)	970

- 3359 Fax	(571)	970

- 3271 www.vinylinfo.org www.vinylindesign.com Page 2 of 2  Initial	direct costs	amounting	to	$200	million	are	required	to	meet	the	proposed	rule	and ongoing	direct	costs	of	$130	million	annually	are	needed	to	compensate	for	poorer	quality resins	produced	to	meet	the	proposed	limits.		When	indirect	supply	chain	and	induced	third party	effects	are	fully	considered,	the	broad	economic	impact	amounts	to	billions	of	dollars as	lost	growth	opportunities	for	the	industry	during	the	next	5	years	are	considered.



##  As	proposed,	small	businesses	will	be	impacted	across	the	country	as	they

ar e	forced	to	adjust	to	lower	quality	resins	or	buy	imports	instead	of	goods produced	in	America.

 There	are	nearly	2,000	PVC	processors	in	the	U.S.,	many	of	which	are	small	businesses. Most	PVC	products	are	manufactured	to	tight	product	specifications	in	th e	medical,	building and	construction,	toy,	packaging,	and	water	infrastructure	sectors,	among	many	others.		If forced	to	reformulate	and	recertify	PVC	compounds	that	compensate	for	poorer	quality	PVC resins,	these	processors	will	bear	an	undue	burden	as	a result	of	EPA’s	regulation,	a	factor that	EPA	and	OIRA	must	weigh	when	considering	the	unintended	consequences	of	an	overly
restrictive	PVC	MACT	rule.



##  The	intention	of	the	Clean	Air	Act	must	be	followed,	which	is	fully	supported by	the	PVC	resin	manufactur ing	industry	in	America.

 We	ask	OMB	to	exercise	their	oversight	and	press	the	EPA	to	allow	for	a	rule	that	is	logical, reduces	emissions,	and	protects	a	critical	industry	in	the	U.S.