Document wg2VYGyqmw5NnmEYob8gB5YoJ

Exhibit A ENVIRONMENTAL MANAGEMENT COMMITTEE REPORT TO THE BOARD OF DIRECTORS SEPTEMBER 8, 1980 CMA 044505 EXECUTIVE SUMMARY Major Accomplishments The Environmental Management Committee's (EMC) 1979-1980 year was extremely hectic, but productive. As highlighted in the last section of this summary, it is conservatively estimated that this oast year's efforts saved the industry hundreds of millions of dollars. It was also a year of change: program expansion, staff additions, structural and programmatic streamlining and management strenghtening. A summary of the Committee's major accomplishments follows: Air Programs o Initial CMA Clean Air Act amendments position established for next year's legislative effort. o Significant achievements in working with the Environmental Protection Agency (EPA) at the early stages of its regulatory development program of New Source Performance Standards, NESHAPS, and CTG's. A CMA suit against EPA on disapproving a portion of the New Jersey State Implementation Plan (SIP) is aimed at eliminating the need for SIP revision and EPA approval for every proposed application of the bubble concept. o Prevention of Significant Deterioration (PSD) litigation and subsequent rulemaking comments submitted to EPA resulted in a generally favorable decision and revised regulations. Water Programs o Worked with EPA to significantly improve the cost-effective ness and scope of the agency's Best Management Practice program. o Successfully advocated effluent guidelines policy position which led to EPA dropping its uncessarily costly ($140,000,000) wastewater self-monitoring program. Instrumental in devel oping joint CMA/EPA biotreatment study. (See item 1, General Purpose Programs, page ii.) o Initiated valuable inter-trade association coordination on significant water issues. i CMA 044506 o Completed 35 position papers and responsive comments on proposed rules to influence both Federal and State Water regulatory development efforts. o Closely following EPA's Publicly Owned Treatment Works (POTW) program to ensure last year's litigation settlement gains are not lost. Solid Waste Programs o A strong advocacy position was continued on EPA developing Resource Conservation Recovery Act (RCRA) regulatory program CMA's leadership has played a major role in improving the cost-effectiveness of the final rules. This leadership was continued with the filing of a petition for judicial review of unacceptable provisions of the final regulations. o Model state legislation .for the siting of hazardous waste management facilities was developed and is being advocated through member companies. o A workshop on the final RCRA, Subtitle C, regulations was judged exceptionally informative by over 250 attendees rep resenting over 100 chemical companies. o Provided strong technical support, positions, and proposals for CMA's Superfund Program. o Established a Groundwater Management Task Group and imple mented a strong technical, legal and policy program in preparation for anticipated legislative activities in 1981 and subsequent implementing regulations that ultimately may be of greater impact than RCRA and/or Superfund. o Successfully completed the Hazardous Waste Response Center pilot program. General Purpose Programs o Began a CMA/EPA cooperative monitoring program to assess the'efficiency of priority pollutant removal by biotreatment o Established an Environmental Communications Task Group to improve the dissemination of information to member companies and influential audiences. o Provided analytical and economic policy development support to major program area: air, water, and solid waste. ii CMA 044507 kerall EMC/Staff Activities o The EMC further strengthened program structure and management. The overall EMC program was evaluated and critiqued during April/June 1980. Program structure was streamlined from 27 to 23 task groups while expanding specific program areas and task group missions. Program/task group alignment and personnel improvements/ strengthenings are planned. EMC policy and procedures, and task group leadership changes were approved. - All improvements to strengthen the EMC program will be implemented by the end of September. o The CMA Staff role was significantly improved during 1979-1980. Staff was added and trained. Coordination with legal department has further strengthened. Management systems were developed and implemented. - A strong dual staff role of support/guidance was established in partnership with Committee and task group leaders. o The Committee established and implemented programs to strengthen its influence at every stage of the legis lative/regulatory process. These programs are aimed at: Early identification of emerging environmental issues (Environmental Issues T/G). ~ Establishment of aggressive work plan to effectively do our homework on a timely basis (Ex. Groundwater Management T/G). ~ Monitoring and influencing EPA's R&D. Developing CMA position papers at an early stage to influence regulatory agency and/or build grass roots support for legislative activities. ~ Working with EPA and its contractors well before the draft regulation stage. iii CMA 044508 Member Company Personnel The technical and legal expertise of over 200 people from over 50 member companies is currently being tapped to achieve the goals of the EMC. Compared to one year ago, the number of member company personnel on permane e and task group assignments has increased by 21% to 205. The number of companies contributing these resources has increased by 47% to 53. Committee and task group assignments involve policy development and consideration of alternate strategies. It also involves hard workl The current EMC program requires a 50 man year effort level, an increase of 43% free one year ago. This level of effort together with the involvement of many more member companies are two key rea sons for the strength of the EMC program. CMA Staff Personnel The Environmental Division consists of seven professionals and six supporting staff. Additional CMA staff associated with EMC activities include the equivalent of 1H attorneys from the Legal Department, h professional person from the Government Relations Department and assistance from the Communications Department on an "as needed" basis. During the coming year we expect to receive additional support from the Government Relations, Communications and Legal Departments due to more complex and intensive legal, regulatory and legislative activity. The Environmental Division will primarily need additional resources to handle rke increased demand for administrative services. Additional word processing capability will especially be required to successfully support increased staff and task group activity for the development of responsive comments and position documents. IV CMA 044509 Budget Summary Operating Budget Environmental Hazardous Waste Response Center TOTAL Actual 1979/80 414,300 181,200 595,500 Approved 1980/81 535.800 263.800 799,600 Researchand_Consulting__Bud2et Enviromental Hazardous Waste Response Center TOTAL 415,000 415,000 620,000 68,000 688,000 racial Fees and Expenses - Environmental TOTAL =JLr4E 744,900* *Does not reflect special advocacy projects where limited impact on industry. CMA 044510 v Value To Industry The financial/economic impact of the EMC's use of re sources is difficult to measure, especially since the Com mittee's program is becoming more geared to impact all stages of the legislative/regulatory process. However, we conservatively estimate this past year's results in terms of savings in four categories: o Savings due to agency programs not being imple mented prematurely or programs being scrapped by the agency based upon CMA advocacy - hundreds of millions of dollars this year and next. - Wastewater Self-Monitoring - Superfund (EMC support efforts) o Savings due to redirection/modifications achieved on agency programs being developed/implemented hundreds of millions of dollars over the next couple of years. - Nonattainment Regulations - Prevention of Significant Deterioration Regu lations - Resource Conservation and Recovery Act Regu lations - Best Management Practices o Savings due to timely and sound comments/support data/regulatory alternatives during the early stages of agency programs - hundreds of millions of dollars during the next 3 to 5 years. - Effluent Guidelines - Environmental Testing and Monitoring - New Source Performance Standards, Control Technique Guidelines, and National Emission Standards for Hazardous Air Pollutants (current programs) o Savings due to the expected impact of this year's ,efforts in preparation for advocacy strategy to in fluence planned legislation and/or regulations - hun dreds of millions of dollars over the next 10 years. - Clean Air and Water Act Revisions - Groundwater Management Programs - Water Quality Criteria/Water Quality Standards Regulatory Programs - New Source Performance Standards, Control Tech nique Guidelines, and National Emission Standards for Hazardous Air Pollutants vi CMA 044511 The savings are significant in spite of not being highly quantitative. We are initiating a program to more reliably quantify CMA's impact on each step of the legis lative/regulatory process. This will help us set priori ties, evaluate alternative regulatory proposals, and measure performance. Today, however, we can identify the key rea sons for our success: o Strong advocacy posture. o Use of sound science, hard data, and industrial experience. I o Effective and appropriate use of litigation and settlement negotiations. o High level of commitment of member companies and company resources. o Strong staff support and guidance. o Coordination with other trade associations and business groups, o A strong partnership between member company personnel and CMA Staff. o Effective and timely help from other functional groups from CMA and member companies, i o Early involvement and sound management at all ; stages of the legislative and regulatory process. i We will continue to use these concepts as the basis of i our program. We will use additional concepts which work, | and we expect to be able to better quantify next year's performance. i vii CMA 044512