exaggerating the costs?
This is not your typical regulation—it is a whole new approach to regulating air toxics from industry, being applied to one of our nation’s most essential industries. Adoption of this rule will make it difficult to raise the capital or the business confidence to modernize existing cement kilns, will reduce the capacity of kilns, and will make new plant construction almost impossible. Even the EPA, in their proposed rule, estimates that adoption of the proposed rule will result in $340 million in new costs to cement industry, and an almost 10% drop in U.S. cement production. And, these predictions are unreasonably conservative because they do not take into account that the costs of adopting all of the differing MACT technologies simultaneously are inherently unpredictable because there is no cement manufacturing plant that has attempted to use all of these control technologies at once.
