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Issue
Should PIA support legislative or administrative changes to the Clean
Air Act?
Status
No legislation was seriously considered in 2000-2001 to reauthorize the
Clean Air Act.
Concerns
The Clean Air Act has been one of the top environmental issues for printers,
although the effect of the Act on printers really depends on the size
of the company and where the company is located. For companies located
in non-attainment areas (areas not meeting the federal ambient
air quality standards), printers designated as major sources are required
to have site specific permits for their operations that indicate the level
of emission reductions which must be achieved. These permits may limit
the ability of companies to grow without a public review process. Currently,
the overwhelming majority of lithographic printers do not have a federal
permit requirement, although many have to comply with state permitting
rules.
Recently,
PIA/GATF has been working with EPA on a federal air permit template which
would be available for use in any state that is considering expanding
its permitting program to printers. The template should reduce compliance
costs to printers and the state and federal agencies. It is anticipated
that this issue will be addressed by EPA in the next few months.
Any
reform of the Clean Air Act would include new source review requirements,
emission inventories, consolidated reporting and permitting, potential
to emit guidelines, and small business assistance.
- Position
For small companies, PIA supports limiting the application of federal
and state permitting programs. Instead, PIA supports continued expansion
of technical and educational assistance programs as an alternative to
regulatory control. For companies that are subject to permits, PIA supports
programs that consolidate permits and requirements to assure coordination
with other environmental statutes. In addition, PIA supports:
- Review
of emission factors to assure that the U. S. printing industry's
contribution to volatile organic compounds and other regulated air
emissions are accurately determined.
- Credit
for good faith efforts to reduce environmental emissions through
best management practices and educational programs.
- Multi-media
approaches to environmental management and regulations.
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