Document MGr6axX01QyL9pnLrrNj2qgk7

INTEROFFICE MEMORANDUM To E. Donley_________ From J. Diglio DatP 16 July 197 9 Subject Impressions of New CMA and Its Advocacy Role_____________ Executive (Location, Organization, or Oapartmant) Chemicals Mfg. (Location, Organization, or Dapartmant) These comments are based on observations as a member of the "new" CMA Environmental Management Committee and also as a member of the MCA Environmental Committees before the organi zational changes. On this basis, the issues in John Henske's letter are addressed. I hope they will be useful to you. Purpose of the Special Committee, It's Recommendations... CMA Advocacy Role There has been a dramatic improvement in the performance of the EMC environmental activities. Our objectives and missions were defined early and clearly for each EMC Task Group by its Task Group leader and EMC sponsor. The outstanding advocacy role effectively changed regulation for the benefit of industry. It also has changed EPA's role; from polite listener - providing us little or no influence on the regulations; to one of a negotiator - providing us signifi cant beneficial changes in the regulations. Some examples are: Litigation and negotiation of Section 311 Hazardous Waste Spill Regulations Avoided Chemical Industry analytical and monitoring costs, alone, of up to $85 MM. Air Products was a co litigant along with CMA and others. Litigation and negotiation of pretreatment regulation Avoided Chemical Industry costs by obtaining removal credits for in dustrial dischargers to public treatment works of up to $624 MM. Air Products is a co-litigant with CMA and others. Air Product's per sonnel continue to sponsor and lead the Task Group on this issue. (320) AP00025343 E. Donley -2- 16 July 1979 Litigation and negotia tion of NPDES Regula tions Prevention of significant deteriora tion and non-attainment regulations litigation EPA has announced they are willing to negotiate on these regulations with CMA. In a recent court decision, CMA has won several issues that will avoid significant costs for the industry. These advocacy successes are estimated to avoid the chemical in dustry and indirectly our society capital costs of hundreds of millions of dollars for unnecessary pollution control. Present Structure - Implementation of Re-organization Plan The number of committees, task groups and more carefully selected personnel from member companies in CMA environmental activities have been reduced and their effectiveness has increased compared to the previous organizational structure. The Environmental Management Committee consists of 15 members, who sponsor 16 Task Group leaders with five to six individuals per group for a total of approximately 105 people. The issues for the Task Groups were selected on a priority basis. This compares to the previous MCA organization of 3 Environmental Committees of ninety members; 47 Task Groups and subcommittees, totaling 330 people working on many more issues. The improvement in performance may be attributed to the re-organization which: - Caused the CMA staff to be supportive of the activities rather than a bottle neck and source of internal con flict between members of companies and MCA staff. - The direct communications of committee chairman on important issues to executive committee. - The new CMA staff executive personnel. - Increased CMA professional and non-professional sup port activities. - Budget expenditure increase to support the necessary activities. Environmental activities expenditure: AP00025344 E. Donley -3- 16 July 1979 Environmental Committees Expenditure Approximate (M$) FY 1978 1979 1980 R&D Legal Staff 43 0 100 250 500 647 400 400 The CMA staff provided excellent complementary support in a co operative spirit. The MCA has greatly improved their profes sional as well as non-professional supportive services. Their non-professional supportive services could use greater improve ment. The EMC felt that the ability to communicate directly to the Executive Committee on key issues, resulted in its timely approval of funds, appropriate decisions by the Executive Committee and enhancement of the CMA staff and committee activities.' These are key to the improved performance of the new organization. I be lieve these characteristics of the re-organization should be care fully preserved. I feel the re-organization is on course and on target. Preserved Needs - Present and Future I visualize improvement in these areas may enhance CMA effective ness: - Diligently synthesizing efforts of other organizations with same goals as CMA e.g., AIHC, API, SPI, SOCMA, Fertilizer Institute, Pharmaceutical, etc. Aggressively seek out such organization with common goals as CMA and unify their activities towards its achievement. - Provide long range strategies by developing five and ten year goals, objectives and forecasts. - Communications to the private, public and government sectors to improve chemical industry image and present the true facts concerning environmental regulations, benefits and cost to the public. EPA has impressive public relations activity. - Each committee should have responsibility for justifica tion and control of the expenditure of its budgeted funds. However, in order to not pre-empt critical unforeseen non-budgeted activities, an approval mechanism should be provided for the committee e.g., Eckhardt Survey Ques tionnaire data processing will cost a non-budgeted $100 M. AP00025345 E. Donley -4- 16 July 1979 - Communication and laison between complementary CMA committees. - EPA is informally setting guidelines for state legisla tion that may offset the CMA federal legislative and regulatory gains. It is suggested a program be developed by CMA staff for executive committee approval to counter this situation. AJD/bkl A. - AP00025346