The EPA/DOE makes things hard
I know this is going to come as a shock to regular readers so hold onto your hats: the U.S. EPA is trying to ram through a new air quality regulation that will be nearly impossible for a lot of Georgia businesses to meet. The agency has proposed making more stringent the allowable amount of a particulate matter called PM2.5 that’s commonly found in manufacturing and agricultural operations. Now, this also comes after the Department of Energy has required new efficiency standards on HVAC systems. As of January 1 of this year, new energy and efficiency requirements took effect for all newly manufactured HVAC systems be it residential or commercial. More on that can be found here. It’s also projected that the EPA will have new standards within the next year for a different class of refrigerants that have a lower GWP – Global Warming Potential. Yes, that’s an acronym. That said, in this realm, things have gotten more expensive. I bring all this up because my fiancé worked in the HVAC industry and it’s been a topic of concern.
Now, it’s possible that the powers-that-be at the EPA or the DOE have forgotten the very real supply chain and economic consequences of the COVID-related shutdowns. I know that I haven’t – and I’m sure that most of you have not forgotten that either. Many industries are still recovering from supply chain issues.
So, let’s look at what the EPA is up to.
The individual regulations under the National Ambient Air Quality Standards (NAAQS) are reviewed on a regular schedule that provides a measure of regulatory certainty for industries and businesses. The EPA declined to change the PM2.5 standard in 2020, when it was up for review, but the regulators there now want to make changes off-schedule. The schedule is meant to give businesses time to invest in new equipment or make upgrades to what they already have. For instance: these HVAC companies or manufacturers have to buy up new equipment to meet the new standards. This is on top of having to figure out what to do with any surplus of old equipment. By old, I mean less than a year old. That equipment is basically just sunk costs at this point.
In relation to the EPA and what they have been coming up with, lot of companies are still working to come into compliance with the current PM2.5 standard so this new proposal is akin to pulling the rug out from under them. “Haha! You haven’t yet met the existing standard so we’re going to make a new, more stringent one that will be harder to comply with!” That’s what I imagine the nameless, faceless bureaucrats cackling as they typed up this proposed rule.
I don’t think I’m too far off base, though, since the EPA’s own analysis shows that large swaths of the US, including parts of Georgia, will wind up being in nonattainment – that’s EPA -speak for being out of compliance. A new study (https://documents.nam.org/COMM/NAM_Air_Quality_Standards_Analysis_Web_Version.pdf) from the National Association of Manufacturers found that Georgia would have more than 10 counties at risk of exceeding the more stringent.
The economic consequences for being in nonattainment can be severe since any infrastructure project planned in a nonattainment area requires more levels of hoops to jump through to get permits and approvals. It’s not just infrastructure projects; it’s any kind of economic development inside a nonattainment area that would be stymied. According to that NAM study on the economic impacts of this proposal, about 7,600 jobs in Georgia would be threatened, and the state’s economic exposure for manufacturing activity would be around $1.5 billion.
Here’s the dirty secret that the EPA doesn’t want us to know: the agency’s own data shows that PM2.5 levels have dropped by 44% since 2000 and overall, we’ve reduced six common air pollutants by 78% between 1970 and 2020. But yeah, go ahead, EPA, and smash down another set of unnecessary and burdensome regulations to crush our manufacturers just when they’re starting to see light at the end of the shutdown tunnel. Bureaucratic brilliance at its finest.
