Recent reports (http://www.ism.ws/ismreport/mfgrob.cfm, http://www.strategy-business.com/article/00297?gko=0d2ac&cid=TL20141016&utm_campaign=TL20141016) indicate the return to the US of manufacturing after several decades of operations going overseas. “Re-shoring” is being fueled by several factors, including the high availability and dropping costs of diverse US energy sources (i.e., natural gas and renewables), our infrastructure (more reliable than in Asia), improvements in automation and availability of robotics (one estimate states that the American worker is now seven times more productive than the equivalent one in Asia, negating the wage differential), greater ability to respond to changing customer needs and to supply chain disruptions, greater availability of capital, and the ability to perform robust R&D. This trend is also helped by the growth in incentives being offered by a number of states to relocate or expand.

This is wonderful news for the US economy. Manufacturing is the opportunity to take raw material of relatively little value and turn it into something of much greater use and value, allowing a markup and greater profit, in many cases, than in the service economy. Some have estimated that new US manufacturing startups and expansions can grow manufacturing sector jobs by 4 million in the next few years alone.

Having hundreds of new manufacturing plants and processes in the US has many implications, one of which is the environment. Compared to other countries, the US has relatively strict environmental rules. Most such rules are enforced at the state level, but contain minimum standards based on the Federal Clean Air Act and Clean Water Act.

I will focus on Air since that is usually the most time-consuming. If you are building a new plant from scratch or performing a major expansion of an existing one, the first matter to consider (the bottleneck) is a rule called PSD, a pre-construction permit. One is forbidden legally to even begin construction until a PSD Permit is issued. PSD is a lengthy process, often taking many months to over a year for full approval by both the State agency and the USEPA (with public comment). So if your company plans to build or expand, it is important to address this fully and early. Simply put, PSD states that if you propose a major increase in emissions of certain compounds, proper control technology must be installed and modeling performed to estimate how much ground-level concentration will increase to determine whether standards may be exceeded.

The CAA also requires facilities that exceed a threshold of “potential to emit” to apply for and maintain a “Title V” air permit. These permits are legal documents and open to the public, so care is needed to make sure it is prepared properly and, once issued, compliance maintained. The hallmark of a Title V permit application is a listing of all Federal and State air regulations that are applicable to the operations you plan to perform at the new site (or modified existing facility). While the Title V application requires a list of regulations that are applicable to the operations and why, it is just as important to prepare – at least internally – a document explaining why certain rules are not applicable and need not be listed in the application.

Finally, most states have air pollution rules pertaining to specific types of operations, such as boilers and furnaces, coating and painting, pharmaceuticals, iron and steel, and others. Do a thorough review of the laws in your state and determine whether any are applicable (and if not, why) and how best to comply. Also, federal NESHAP rules for toxic compounds are process-specific, as well, and should be reviewed.

Yes, your company may join others in moving manufacturing operations “home” soon and that’s good news for everybody. And yes, that means work for you as the environmental professional to comply with applicable rules. But good preparation and planning can make the situation proceed smoothly and the costs relatively low to the eventual long-term savings and safety improvements.

CCES has the experts to help you estimate emissions from new plants or processes, to research and advise (technically, not legally) on State and Federal air and other environmental regulations that may be applicable to such new operations, and can manage the implementation of strategies and obtain the proper permits to allow you to comply with environmental rules and begin operations quicker and seamlessly. Please contact us today at 914-584-6720 or at karell@CCESworld.com.