By Randy Rawson, President and CEO, American Boiler Manufacturers Association
ICI-BMACT. This little eight-character acronym – short for EPA's National Emission Standards for Hazardous Air Pollutants for Area and Major Sources: Industrial, Commercial, and Institutional Boilers – has been causing agitation in both the commercial andindustrial boiler user and manufacturer communities for a decade … for different reasons. Owners and users have found some past permutations of the rules problematic and expensive to put into practice; manufacturers have been frustrated by what has become a never-ending regulatory process – its end-game constantly being delayed by regulatory data-gathering inadequacies, stakeholder stalling and litigation. The rules promise to be a business opportunity and job creator for the boiler, combustion and allied pollution-control equipment manufacturing industry, so ABMA has fought hard to minimize capricious delays over and above those absolutely necessary to insure that all viewpoints and technical issues are given a thorough hearing.
After multiple attempts by EPA over the last decade to collect meaningful user data on which to base its ICI-BMACT rules, EPA issued final ICI-BMACT rules in early 2011 under pressure by impatient courts. At the same time the "final" rules came down, EPA initiated a Reconsideration of those same rules in an attempt to refine them even more in response to ICI-BMACT naysayers. The Reconsideration prompted additional boiler operations data and voluntary input from the boiler user community, driving EPA to adjust its thinking to embrace more practicality and flexibility in the rules' application – an approach that, in ABMA's opinion, was amplified even more by EPA when it proposed new Reconsideration ICI-BMACT rules in December 2011. EPA then provided yet another 60 days for stakeholders to review, comment and tweak any perceived left-over technical issues from previous rulemakings.
After over a decade in the making, boiler manufacturers are looking forward to late spring or early summer 2011 to a final set of Area and Major Source rules from EPA that not only achieve the objectives of the Clean Air Act but which do so with a realistic, common sense and pragmatic approach.
That is, unless an ill-informed Congress intervenes at the last minute and mandates an additional delay of 15 months or more.
Some in Congress have labeled the boiler and combustion equipment industry as incompetent to meet the rules' mandates, have demonized the rules as job-killers, and have claimed that there are insufficient domestic manufacturing resources to comply with the rules within the time frames set by EPA. ABMA has pushed back against these charges and continues, in defense of the boiler and combustion equipment manufacturing industry, to combat such fallacious assertions with facts to the contrary.
Compliance with EPA's new December 2011 ICI-BMACT Rules can be achieved with existing, affordable, state-of-the-art, technologically-advanced and fuel-flexible products, along with innovatively-designed-and-engineered application solutions, provided by the U. S. boiler manufacturing industry to meet the exigent needs of a host of varied individual boiler facilities impacted by ICI-BMACT. Implementation may not be cheap or easy, but it's entirely doable.
As for compliance resources, ABMA members like those highlighted in the following pages of advertising and those listed in the ABMA-Member Buyers Guide at http://abma.com/abma_guide_2011-12.pdf, stand ready and able right now to help those affected by these rules to comply with them in a timely and affordable manner. Arguments that there are insufficient resources available for use in compliance within the time period specified by the rules are baseless and uninformed in the extreme. In fact, further delay in rolling out what are inevitable final rules will only exacerbate future compliance issues and costs.
Labor and materials costs are currently stable and domestic boiler and combustion equipment manufacturing capacity is available now to service the full range of compliance options available under the new, more flexible rules as proposed by EPA last December. ABMA members form a proud domestic manufacturing legacy, and they are prepared to meet any compliance challenges that any air quality rules might generate in an affordable fashion.
Contrary to what some too-frequently-cited yet flawed and discredited studies would have lawmakers believe, these proposed rules are not job-killers – in fact, for the boiler, combustion, pollution-control and for other compliance-related industries, they may be job generators. They are clearly job generators for those small businesses on main streets across this country that install, repair and tune-up boilers and boiler systems.
Although Congress is well-versed in kicking the can down the road, after more than a decade of information gathering, proposal and debate, there is no reason for arbitrary Congressional intervention at this point in the process. Congress shouldn't let the preoccupation by some with the inadequacies of past rulemaking efforts lead them into arbitrarily delaying the current December-initiated rulemaking process – proposals and a process that provides a flexible, affordable, and achievable pathway to air quality, greater efficiency and the types of long-term boiler room upgrades and modernizations that will lead to sustainable competiveness and bottom line stability. All involved need to bring this rulemaking process to a responsible and timely conclusion so that a measure of market certainty can be brought about and everyone can get on with the planning and investments that will be necessary.
Members of the ABMA like those in the pages that follow bring to the table a unique and innovative technical and production expertise to help commercial, institutional, industrial, heat recovery and power-generating boiler systems owners and operators cope with rapidly changing environmental and market demands and expectations and to achieve corporate success in their energy divisions.
Founded nearly 125 years ago by self-regulating boiler manufacturers in search of safe, uniform boiler design techniques and materials, the ABMA of 2012 is composed of diverse companies providing a wide spectrum of proficiencies, products and services to meet just about any energy and comfort heating need. A member company of the ABMA is not just another steam, hot water or combustion equipment company ... it is part of a tradition of excellence and a legacy of achievement, and, through its affiliation with the ABMA, signals an exceptional commitment and obligation to the market, to its customers and to the public.
For more information go to boilermactfacts.com.
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