Document 2J5gjoVnNLyOQ3M7KX5QLBNo7

PCA is the voice of America's cement manufacturers. Founded in 1916, the Portland Cement Association (PCA) is the premier policy, research, education, and market intelligence organization serving America's cement manufacturers. Our members are responsible for 92 percent of U.S. cement production capacity and have facilities in all 50 states. The association promotes safety, sustainability, and innovation in all aspects of construction, fosters environmentally responsible continuous improvement in cement manufacturing and distribution, and generally promotes economic growth and sound infrastructure investment. For more information, visit www.cement.org. What is portland cement? r j< / i ( jmbers have long been committed to making our high qualb , | r >ducts safely am biciently while Portland cement is the general term for the type of cement used in virtually all concrete - one of the most durable, resilient and sustainable construction materials used to build American homes, buildings, and vital infrastructure. Cement is produced by grinding limestone, which is then blended with other raw materials like clay and sand. The mixture is then heated in a large industrial kiln to form an intermediate product called clinker. Once cooled, the clinker is ground with gypsum, limestone, and other additives into the fine gray powder known as portland cement. reducing our environmental footprint. Cement manufacturers are dedicated to resiliency, efficiency, and sustainability. The U.S. cement industry has long been committed to making highquality products safely and efficiently, while reducing our environmental footprint. Cement manufacturers have significantly reduced their use of energy, cutting the amount of energy used to produce a ton of cement by over 40 percent during the past 40 years. To do so, the industry has focused on energy efficiency, equipment reliability, and use of alternative fuels, including those with significant biogenic content. The industry has reduced its use of traditional fossil fuels, such as coal and petroleum coke, with alternative fuels now accounting for over 15 percent of total plant energy Page 1 of 4 17cv01906 Sierra Club v. EPA ED 001523B 00001614-00001 consumption. In 2015, U.S. cement kilns burned approximately 46 million scrap tires, totaling 753,370 tons in weight. Combined with significant investments in air pollution controls, energy efficiency gains also have led to dramatic emissions reductions. Thanks to work by the cement industry and other large facilities, air quality in the U.S. has improved drastically, with industrial air emissions down 70 percent since 1970. energy and resources. The industry is also a leader in sustainable material use and management, including reuse of industrial products as ingredients to make cement. Cement manufacturers often use alternative raw materials from industrial byproducts, such as those from coal combustion, steel blast furnace slag, and silica fume, keeping a large portion of these materials from being disposed of in landfills. The durability and resiliency of cement-related products also lower our environmental footprint. Concrete does not rust, rot, or burn, saving energy and resources needed to replace or repair damaged buildings and infrastructure. Because of its rigidity, concrete pavement can enhance the fuel efficiency of vehicles that travel on roads when compared to other pavements. If concrete pavements were used by the U.S. road system, fuel consumption is estimated to decrease by 3 percent nationwide, equating to a reduction in fuel consumption of 273 million barrels of crude oil a year, and a corresponding reduction decrease of greenhouse gas emissions by 51.2 million short tons. The energy efficiency of buildings also improves when concrete is used. A concrete construction home has been demonstrated to require 6-12 percent less energy than code-compliant wood frame construction. 17cv01906 Sierra Club v. EPA Page 2. of 4 ED 001523B 00001614-00002 o " public policy priorities are wellaligned with the new Congress and Administration, PCA's public policy priorities are well-aligned with the new Congress and Administration, and we look forward to working with you to: Implement sensible regulatory reform. We need sensible reforms to make sure that federal regulations are necessary, effective, based on sound science, and ensure the highest degree of flexibility and the lowest burden on U.S. manufacturers. The Administration should require robust cost-benefit analyses for all new regulations with an emphasis on the impact on jobs. Federal agencies' review of benefits should focus on direct and measurable outcomes based on rigorous scientific review and evidence, not hypothetical projections or secondary benefits. Rebuild our nation's infrastructure. America's cement producers support efforts to: Expand oil, gas and other pipeline development to assure low-cost domestic energy, boost the economy and provide great jobs, while conserving our Nation's bountiful natural resources; Invest in new coastal infrastructure to protect against natural disasters; Rebuild America's roads and bridges, with an emphasis on resilience; Put measures in place to make sure taxpayer money is spent with longevity in mind, so we get the most out of our investments in the future; Create tax incentives for private sector investment in infrastructure to pair the best the private sector has to offer with the public's infrastructure; Expand the use of public/private partnerships; and Modernize our electric grid. Protect our environment. PCA members take environmental stewardship seriously, and we're proud of our record. We support efforts to focus environmental regulations on protecting Americans from known risks to public health based on sound science and evidence. Wherever possible the federal government should utilize marketbased incentives for emissions reductions and incentivize the development of new technologies. o The primary role of implementing and enforcing environmental standards should be restored to state and Page 3 of 4 17cv01906 Sierra Club v. EPA ED 001523B 00001614-00003 local regulators, who are closest to the environmental impacts and operations of the facilities within their jurisdictions. Protect our workers. PCA members place the safety of their employees among their highest priorities and core values. PCA is proud that the industry's commitment to safety contributed to the federal government's recognition of 2015 as the safest year on record for Metal and Nonmetal Miners, which includes our industry. We support efforts to modernize the agencies responsible for administering health and safety laws and to make sure regulations focus on evidence-based efforts to reduce injuries and improve outcomes. We support efforts to improve safety performance that are based on sound Occupational Health and Safety Management Systems, employee engagement, risk reduction and behavior based safety. We will continue to work with agency and industry leaders to minimize or eliminate hazards by promoting new and innovative training resources, ensuring the continual development of safe handling procedures and the sharing of best practices. 17cv01906 Sierra Club v. EPA Page 4 of 4 ED 001523B 00001614-00004