• Coalition Comments on the Financial Responsibility Requirements Under CERCLA Section 108(b) for Facilities in the Chemical Manufacturing Industry

Letters
May 6, 2020

Dear Ms. Mooney:
The U.S. economy is powered by a diverse energy and manufacturing portfolio, unmatched by any other nation in the world. Through innovation, responsible development and use of all energy sources, American industry has established a strong record in environmental protection and fully supports the ongoing national effort to protect our environment and improve public health, even in the face of the current pandemic. We, the undersigned organizations, submit the following comments to the U.S. Environmental Protection Agency (“EPA” or “Agency”) in support of the proposed rule, “Financial Responsibility Requirements Under CERCLA Section 108(b) for Facilities in the Chemical Manufacturing Industry” (“Proposed Rule”).1

Our members have a substantial and direct interest in the outcome of this rulemaking. Some of our members own and operate chemical manufacturing facilities; others provide the equipment and materials needed to run those facilities; and many are consumers of products manufactured by this industry. As such, it is important that EPA does not impose burdensome and unnecessary financial responsibility requirements on this industrial sector. Our members also have a vested interest in EPA’s process for evaluating financial risks when deciding whether to promulgate regulations for any industry sector under Section 108(b) of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (“CERCLA” or “Section 108(b)”).2