Just about everyone favors protecting the environment, but
few have done as much as the members of the American Fuel and
Petrochemicals Manufacturers (AFPM)
to improve the US air and water quality.
Members of AFPM (formerly the National Petrochemical and Refiners
Association, or NPRA) are strongly committed to environmental
protection. We have an outstanding record of compliance with
the Clean Air Act, and have invested hundreds of billions of
dollars to dramatically reduce emissions as measured by the US
Environmental Protection Agency.
As a result of our emissions reductions and reductions
by other industries, the US air today is cleaner than it
has been in generations.
EPA data shows that total emissions of the six principal air
pollutants in the US have dropped by 57% since 1980 and ozone
levels have decreased by 30%. These reductions occurred even as
industrial output has increased. And the EPA expects there will
be continued reductions in the years ahead under regulations
already in place.
Today, US refiners manufacture the cleanest fuels in the
world and emissions are lower than anywhere else. Our products
and facilities are cleaner than those in
any other nation. Our investments have resulted in significant
cuts in sulfur levels in gasoline, reducing them by 90% just
Between 1996 and 2005, refiners cut emissions of chemicals
listed under the Toxic Release Inventory by 36% and reduced
emissions classified as hazardous air pollutants by 50%. The
comparable reductions by chemical manufacturers in the same
time period are 61% under the Toxic Release Inventory and 64%
of hazardous air pollutants.
Despite the great progress that has been made, we are
concerned that the EPA and other government agencies have moved
from reasonable regulation to overregulation that makes
unrealistic and often conflicting demands on fuel and petrochemical manufacturers. These
demands frequently have little or no significant environmental
benefit but cost millions, and even billions, of dollars to
meet, increasing energy costs for US consumers.
One example is the proposed rule by the EPA to further
reduce sulfur levels in gasoline. EPA is proceeding with what
is known as a Tier 3 rulemaking as part of its general
authority to regulate fuels under the Clean Air Act. The rule
could lead to significant domestic fuel supply reductions,
higher petroleum product imports, increased consumer costs,
increased refinery emissions, the closure of
US refineries that would leave their workers unemployed, and
reduced energy security.
Another example of overregulation involves gasoline
containing 15% ethanol, or E15. EPA decided to
allow E15 to be sold into the marketplace for use in cars and
light trucks produced in model year 2007 and later, and then
for model year 2001 and later. In addition to being what we
consider a violation of law, these decisions hold the potential
to create significant problems in the marketplace, including
misfueling and engine damage.
The impact of overregulation is clear to see. A Department
of Energy report issued in 2011 found that refining margins have been
continuously decreasing over the past four years. The report
also concluded that the compounded burden of federal
regulations was a significant factor in the closure of 66
petroleum refineries in the US in the past 20 years.
Just since 2008, the recession and refinery closures have led to 3,000
lost jobs at US refineries. A handful of refineries are
threatened with closure in the near future if they cannot be
sold. Although some of the lost supply from shuttered
refineries has been made up through capacity expansions at other facilities, the rate of new capacity
coming online is decreasing due to financial pressures and the
threat of overseas competition.
Those lost American jobs arent simply disappearing,
they are moving overseas to foreign competitors not strangled
by burdensome environmental and other business
Foreign industries emit greenhouse gases (GHG) into the
common atmosphere that every nation on Earth shares. GHG emissions produced in China have the
same impact on our environment as emissions generated in the
United States. Simply shifting emissions from the US to other
nations has absolutely no environmental benefit, but great
economic cost here at home.
Sadly, todays environment of overregulation serves
only to strengthen foreign competitors eager to replace US
manufacturers and workers. It will continue to weaken the US
economy, make the US more reliant on nations in unstable parts
of the world for vital fuels and petrochemicals, and endanger our
The US does not need to choose between a healthy environment
and a healthy economy that provides more jobs for our citizens.
We can have both. We are not calling for a repeal of existing
environmental regulations that have led to major improvements
in our environment and that will lead to continuing
environmental improvement without further change.
We are calling for reasonableness and common sense. It is
unreasonable to say that the US will spend billions of federal
tax dollars to subsidize inefficient and unpopular new energy
sources, deprive many thousands of workers of their jobs, and
severely damage the US economic and national security in
the overzealous pursuit of small emissions reductions that have
little or no significant environmental benefit.
Instead of serving the US people, such environmental
extremism does far more harm than good. Our government needs to
use objective analysis to determine when the costs of
overregulation exceed the benefits, and to act in the best
overall interest of people in the US. HP
Charles T. Drevna is the president of
the American Fuel and Petrochemical Manufacturers
(AFPM), a national trade association with more than 450
members, including those who own or operate virtually
all US refining capacity and most
all petrochemical manufacturers
in the US. Prior to his election as president in 2007,
Mr. Drevna served as AFPMs executive vice
president and director of policy and planning. Mr.
Drevna has an extensive background in energy,
environmental and natural resource matters, with more
than 36 years of broad energy industry experience in
legislative, regulatory, public policy and marketplace
issues. Prior to joining AFPM, Mr. Drevna served as
director of state and federal government relations for
Tosco, Inc., the nations largest independent
petroleum refiner, where he was responsible for liaison
with Congress, federal regulatory agencies and state
governments. Mr. Drevna also served as director of
government and regulatory affairs for the Oxygenated
Fuels Association, where he held similar
responsibilities, and as vice president at Jefferson
Waterman International, a Washington, DC-based
consulting group, where he specialized in domestic and
international energy issues. Mr. Drevna also served as
vice president of public affairs at the Sun Coal Co., a
Knoxville, Tennessee-based unit of Sun Co., Inc.
(Sunoco), and with the parent company as manager of
public policy at its corporate
headquarters in Philadelphia, Pennsylvania. Mr. Drevna
has a significant background in environmental
management that includes service as director of
environmental affairs for the National Coal Association
in Washington, DC, and as supervisor of environmental quality
control for the Consolidation Coal Co. in Pittsburgh,
Pennsylvania. He received his BA degree in chemistry
from Washington and Jefferson College and performed
graduate work at Carnegie-Mellon University.