Regulatory Pressures Affecting Manufacturing in Contra Costa County Peter McGaw A R C H E R N O R R I S on behalf of The Contra Costa Council Presented.

Regulatory Pressures Affecting Manufacturing in

Contra Costa County

Peter McGawA R C H E R N O R R I S

on behalf of

The Contra Costa Council

Presented to The Contra Costa County

Board of SupervisorsOctober 28, 2003

The Contra Costa Council

A collaboration of business, labor, government, education and non-profit organizations

Nearly 400 members provide approximately one quarter of the employment in Contra Costa County

Dedicated to improving the quality of life in Contra Costa County and in the Bay Area

Changes in the Regulatory Climate

Water Quality

Air Quality

Environmental Justice

Precautionary Principle

New Water Quality Regulation

New rules California Toxics Rule TMDLs

New interpretations of existing rules Narrative Toxicity Criteria

Virtually every permit adopted in the Bay Area in the last three years has been appealed

New Air Quality Regulation

Title V

Ozone and NOx Attainment Plans

Refinery Flaring Rule

Message Received

Placing regulatory burdens on those who have done the most already

Point sources (Water) Stationary sources (Air)

Least benefit for the cost incurred

Environmental Justice

The Contra Costa Council actively supports the fair treatment of all, regardless of race,culture, or economic status, with respect to the development, adoption, implementation and enforcement of environmental laws

Need clear criteria before declaring an issue to be “EJ”

Precautionary Principle

No activity is entirely risk free

Precaution is appropriate where risk of harm cannot be precisely characterized

Our current regulatory system has considerable precaution already built in:

conservative assumptions safety factors low acceptable risk levels

Precautionary Principle

“Where an activity raises a threat to human health or the environment, precautionary measures should be taken even if some cause and effect relationships are not fully established scientifically.”

Recommendations of Advisory Committee to Cal-EPA Interagency Working Group on Environmental Justice

The Precautionary Principle advocates an extreme form of precaution:

Precautionary Principle

Replaces science with unquantifiable “threats”

No standards, no procedural criteria

Easily subject to misapplication and abuse

The Precautionary Principle advocates the abandonment of sound scientific investigation as a basis for environmental decision-making

Precautionary Principle

Allows regulation based on unsubstantiated allegations

Requires the impossible: prove a negative

Precautionary Principle

Adds to cost of products to consumers

Drains regulatory resources chasing imaginary or negligible risks

Allows no consideration of potential benefits

Stifles innovation

Precautionary Principle

Products that would not have passed the test

Aspirin and other medications

Airplanes

Automobiles

Precautionary Principle

Environmental advocates: stop chlorine disinfection due to potential byproducts

Peru: 1.3 million people contracted cholera

Over 11,000 people died

One of Latin America’s biggest cholera epidemics

All to avoid a handful of purely speculative cancer cases

• Chlorine disinfection of drinking water

Precautionary Principle

Electricity

High yield crops

Radar

• CT and MRI Scans

Environmental Regulation

Science, not speculation

Conclusion

Manufacturing is important, to California and to Contra Costa County

Good, high-paying jobs Best job multiplier

Manufacturing is imperiled in this County and across the state

Conclusion

Decisions at the County level can make Contra Costa business-adverse or business-friendly

Advocacy at the Regional and State level can help preserve Contra Costa County’s important manufacturing base

California Manufacturers

& Technology Association