NAM Weighs In On EPA’s Proposed Cost-Benefit Analysis Reform

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In June, EPA announced it would solicit public input on whether and how to change the way it considers costs and benefits in making regulatory decisions. As was first reported in Politico on Tuesday, the NAM filed comments outlining manufacturers’ priorities for reform and listed numerous examples of flawed and costly rulemaking.

The NAM’s comments included the following recommendations:

  • If costs and benefits will accrue over a 30-year time horizon, the Agency should provide cost and benefit estimates for the whole time horizon, not simply a snapshot of what costs and benefits would look like in a given year within the range.
  • When compliance with a rule is based on unknown controls, EPA must base its calculation of those unknown controls on realistic assumptions.
  • When costs and benefits will accrue to the whole economy, EPA should model the impact on the whole economy, not just a part of it.
  • The Agency should avoid relying on outdated data, studies and methodologies, and it should similarly avoid being overly speculative.
  • The Agency can achieve the consistency and specificity it seeks through statute-specific rulemakings that allow for more tailored approaches reflecting the unique statutory requirements.

As I wrote in our filing:

Manufacturers strongly support EPA’s mission. Moreover, the benefits of appropriate regulations are clear and supported by the public. The issue is how to enable the regulatory system to address legitimate concerns without unreasonably impeding innovation, research, development and product deployment. Too often in the regulatory process, the vital national public policy objectives of international competitiveness and technological innovation are given short shrift due to other competing mandates. In order to protect public health and the environment, the NAM supports a regulatory process designed to adhere to sound principles of science, risk assessment and robust benefit-cost analysis … In our view, there are three pillars of effective regulatory cost considerations: transparency, scientific integrity and accountability. In other words, the rule-making process should be conducted out in the open and backed up by objective, unimpeachable science, while being overseen by officials who are held accountable.

The NAM’s full comments can be viewed here.

Engineers say “GO!”

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It’s that time of year when many of us embark on the American tradition of piling the family into the car with an assortment of snacks and suitcases. For some families the destination is the cool mountains, for others a sunny beach. But far too often we quickly find ourselves parked on the highway wondering why our roads seem more like parking lots.

That frustration increases when state or local governments try to eliminate bottlenecks and expand popular routes—only to be blocked by the traffic-jam of federal government permitting. Most people understand that funding is hard to come by, but most people don’t realize that the Clean Water Act (CWA) can cause permitting delays and even block projects. While the law was intended to protect our critical water resources, years of lawsuits and bureaucratic overreach have twisted the law into a giant federal STOP sign.

We have been working to fix this. Manufacturers’ ability to compete and grow depends on a superior infrastructure system that is second-to-none. When building an infrastructure project, time is the most valuable commodity, so streamlining CWA permitting is a top priority.

Manufacturers asked the courts to throw out federal overreach under the CWA. They agreed. We called on the president to restore the law and protect our waters. He agreed. We asked the Corps of Engineers and the Environmental Protection Agency to provide clarity. And they got to work.

Now the Corps of Engineers is taking an important step towards the clarity we have been asking for with a new order that empowers states to play a stronger role in permitting projects. This is a big win for commonsense and a big win infrastructure. In a simple 3-page memo, the Corps provides long-awaited clarity. It empowers the people of every state to take the lead.

For too long, our nation has relied on the infrastructure we inherited from previous generations. But targeted, substantial investments in modernizing our nation’s infrastructure will create jobs, boost economic growth, save lives and help secure America’s mantle of economic leadership in the world. Manufacturers are excited about this important step in the right direction and a chance to hit the open road again.

Creators Wanted: BASF Testifies on Upskilling America Following Key White House Workforce Announcements

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Last week, I joined President Donald Trump and many of our nation’s workforce leaders as he signed an executive order on a new national workforce strategy. That’s something the National Association of Manufacturers had been urging our country to undertake, particularly the emphasis on apprenticeships and training, to prepare more Americans for the technology-intensive modern manufacturing jobs, some 441,000 of which are currently unfilled. It is a bold, smart and necessary action, at a critical time. And again today, President Trump is continuing the drumbeat at an event in Iowa, speaking with manufacturers and placing a needed spotlight on workforce development.

Think about this: If we don’t change minds about manufacturing and upskill our nation’s workforce, we’re looking at an employee shortage that, according to The Manufacturing Institute and Deloitte, could be as high as 2 million by 2025.

So today, the urgency to act and do it right took center stage before a Senate committee addressing apprenticeships and future workforce needs, as Glenn Johnson, workforce development leader at BASF Corporation, provided not only his company’s but his own personal perspective.

In the United States, BASF has more than 15,000 employees across 148 locations, of which 74 are production sites and 18 are research and development facilities. BASF is a leader in building the workforce of the future and encouraging STEM careers. Since 2010, more than 410,000 schoolchildren have participated in BASF’s science education programs. And the company is moving aggressively with “Sequence Apprenticeships” and enterprise-wide programs to support future workers.

As Johnson told the committee, he was living in a trailer park with only a high school diploma 22 years ago, when he started his first manufacturing job. He ran assembly lines and stacked cases of product, eventually progressing to leadership roles and taking advantage of a tuition reimbursement program and training and education to climb up the professional ladder. His is a story of how manufacturing and training can change lives for the better.

And his testimony offers a message of how we can do more of that for more Americans. Click here to read the full text of Johnson’s testimony.

President Trump called on the business community to join his effort—to upskill America. Fortunately, our country has manufacturers like BASF already stepping up to help lead, and organizations like The Manufacturing Institute are dedicated to helping manufacturers attract, train and retain the future workforce.

In Bogota, Brasilia and Buenos Aires: Innovation and Intellectual Property Matters

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Manufacturers in the United States are the world’s leaders in invention and discovery, resulting in not just millions of jobs here at home but also the improvement of lives all around the world. But not every creative spark that helps humanity happens in our borders, and not every idea that benefits U.S. manufacturing or the American people starts on our shores.

Americans rely on innovation from wherever it springs. From health care to environmental technologies, from autonomous vehicles to the latest in information technology, innovation and intellectual property (IP) give rise to products and technologies that enhance everyone’s economic future and quality of life, while giving consumers access to the best choices for what they need. And for manufacturers in the United States specifically, innovation to create these products and technologies is our lifeblood.

That is why it is baffling that many governments around the world have taken shortsighted approaches to IP by implementing policies that undermine IP rights or impose unnecessary regulation. As opposed to pro-growth policies that ensure strong IP protections and remove trade barriers to innovative products, governments are adopting approaches that not only harm manufacturers, large and small, in the United States, but also cripple domestic innovators in these markets by hampering their ability and incentives to innovate.

Latin America is a growing hot spot for these protectionist policies, with a growing number of domestic policies intended to promote compulsory licensing, to narrow the ability of inventors to receive patents and expand regulations that undermine critical research and development and seize confidential business information. These efforts have been seen across the region, in countries from Colombia to Chile, from Brazil to El Salvador, from Argentina to Peru. And these anti-innovation policies are having an impact on their economies. It is no coincidence that this year’s Global Innovation Index shows Latin America as lagging many other regions in innovation, and that its rankings relative to other regions have not improved, nor that its top-performing country (Costa Rica in 2013; Chile in 2018) has fallen by eight places over the past five years.

Such approaches not only rob Latin America of critical access to high-value products and technologies, but they also hurt us all and squander an important opportunity to promote entrepreneurship and growth in manufacturing.

As a community of manufacturers and innovators, who seek more competition—not less—for new ideas and new discoveries, we’re urging Latin American governments to rethink their shortsighted approaches and strengthen the environment for innovation and protection of IP. Their people and their economies depend on it, and the world would be better for it.

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