The current ESL policy will cause business owners to locate new production capacity and employment outside of Texas. The case-by-case permitting policy is not transparent or predictable enough for business owners to rely on. Increased production of non-rusting components for highway bridges and major components for wind energy production, for example, will be very limited in Texas because of the ESL policy.

Prior to the TCEQ stakeholders meeting, ACMA hosted a lunch for industry members at a nearby hotel. In addition to discussing the Standard Permit, the 25 industry members participating received a briefing on the proposal by the National Toxicology Program to list styrene as a “reasonably anticipated” carcinogen, and on ACMA’s Risk Communications Program.

ACMA will submit written comments on the TCEQ Standard Permit by the Jan. 7, 2010 deadline.