ABI and Members in the News

COMMENTS BEFORE THE IOWA ENVIRONMENTAL PROTECTION COMMISSION

Michael Ralston 

Good Morning, Chairperson Hubbell and Members of the Commission, my name is Mike Ralston and I am the President of the Iowa Association of Business and Industry (ABI). ABI represents approximately 1,400 member companies who employ 300,000 hardworking Iowans. Thank you for the opportunity to comment and for your service to the state. ABI members work hard to protect their employees and the citizens of the state by implementing safeguards to protect the environment. Currently, Iowa’s employers are struggling to keep their businesses successful and to keep Iowans employed. 

The agenda today has one action item that would be devastating to Iowa business and industry if implemented by EPA. The letter requesting the EPC to support an EPA declaration defining coal combustion byproduct as a “hazardous waste” would be costly to Iowans and would not result in increased environmental protections. ABI believes any environmental regulation should be based on sound science and regulatory guidance. The science behind declaring all of Iowa’s coal combustion byproducts hazardous waste is simply non-existent and it is contrary to the state’s economic interests and waste reduction goals.

ABI has previously submitted formal comments to the DNR on coal combustion byproducts and their many beneficial uses. If coal combustion byproducts are incorrectly labeled a hazardous waste, these uses would go away along with the jobs and economic and resource conservation benefits they provide. State highway departments, educational institutions and health care facilities are just a few of the public entities that would suffer economic consequences. Some Iowa businesses may be forced to close due to increased fuel, raw material and disposal costs. 

Additionally, organizations such as ECOS (Environmental Council of the States) and ASTSWMO (Association of State and Territorial Solid Waste Management Officials) have submitted information showing CCB is not hazardous. ABI would encourage you to reference those documents when making your decision. The Iowa DNR has put regulations in place to protect Iowans and those regulations have worked. The US EPA has developed a very thorough and effective Industrial Waste Guidance which has been utilized by many states to safely regulate CCB’s. ABI maintains the current DNR regulation of coal combustion byproduct for beneficial uses where appropriate, and utilizing the framework already established in the EPA Industrial Waste Management Guidance Document where gaps exist (if any), will continue to protect Iowa’s most valuable resources; its citizens, its economy and its environment. 

ABI and the 1,400 members it represents strongly encourages the EPC and the DNR to evaluate sound scientific evidence from Iowa sources of coal combustion byproducts, which clearly demonstrates the material is not hazardous waste. The alternative is to forgo the beneficial use of this material and to transport the commodity to other states for disposal to the detriment of Iowa’s citizens and businesses.

ABI appreciates the opportunity to work with the Department and the EPC on this very important issue to all Iowans and the Iowa economy. 

On behalf of the 300,000 hardworking Iowans and the industries they represent, ABI requests you take no action on the letter in question and to maintain your current prudent course. Thank you again for your time and consideration of our request.