Dear Administrator Wheeler: The Pennsylvania Manufacturers’ Association supports the proposal to include cost-benefit analysis in the Department of Environmental Protection (EPA) rulemaking process. Founded in 1909 by Bucks County industrialist Joseph R. Grundy, the Pennsylvania Manufacturers’ Association is the nonprofit, statewide trade organization representing the manufacturing sector, it’s 570,000 employees on the plant floor, millions of additional jobs in supporting industries, and more than $93 billion in gross state product in Pennsylvania’s public policy process.
Pennsylvania’s business community recognizes that without a healthy and sustainable natural environment it is difficult to maintain and attract high quality employees. However, it is equally important to ensure that environmental regulation is approached on sound scientific evidence to ensure that regulations are reasonable and within technological limits. It is likewise prudent that these regulations actually achieve real environmental benefits and do not advantage one sector of the economy to the detriment of another while acknowledging and quantifying all economic impacts.