Letters & Comments

Read ACA’s letters and comments submitted to regulatory bodies and elected officials.
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ACA Joins Letter to IRS on Superfund Chemical Taxes

ACA joined several other organizations representing American businesses subject to the excise taxes, reinstated by the Infrastructure Investment and Jobs Act, on certain chemicals and imported chemical substances under Internal Revenue Code sections 4661 through 4672 beginning July 1, 2022 (the “Superfund taxes”). ACA and others asked IRS for additional clarity on the process by which eligible companies may receive a refund on paid Superfund taxes.

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ACA Joins Multi-Organization Letter to EPA on CARB Locomotive Request

In the letter, the organizations raise serious concerns about an authorization request from the California Air Resources Board (CARB) pertaining to rail locomotive emissions. This regulation from CARB has the potential to create significant disruptions in the supply chain for all sectors of the U.S. economy, especially manufacturers and shippers who rely on consistent, reliable rail service.

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ACA, Coalition Comments to Congress on Recent RMP Amendments

ACA was among 14 organizations that submitted joint comments to the Congress seeking support for legislation, H.J.Res.123, that disapproves of the recent finalized amendments to the Accidental Release Prevention Requirements: Risk Management Programs Under the Clean Air Act; Safer Communities by Chemical Accident Prevention (“RMP rule”).

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ACA Comments on EPA’s Draft Criteria for Product Category Rules to Support the Label Program for Low Embodied Carbon Construction Materials

ACA submitted comments to the U.S. Environmental Protection Agency (EPA) on its Draft Criteria for Product Category Rules to Support the Label Program for Low Embodied Carbon Construction Materials. EPA is developing a program to identify and label construction materials and products that have substantially lower embodied carbon as part of the Inflation Reduction Act. This is in coordination with General Services Administration and Department of Transportation Federal Highway Administration.

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ACA Supports Clarification of Build America, Buy America Requirements

In its letter to the U.S. House Committee on Transportation and Infrastructure Subcommittee on Highways and Transit, ACA expressed support for efforts to better understand the current  administration’s implementation of Build America, Buy America, including those provisions that were in the Infrastructure Investment and Jobs Act.

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ACA Urges Immediate CFATS Reauthorization

ACA and a coalition of other organizations urged Congressional leadership to reauthorize the critical Department of Homeland Security Chemical Facility Anti-Terrorism Standards (CFATS) program that expired July 28, 2023. The CFATS program's primary mission is to help reduce the risk of a terrorist attack on the highest-risk chemical facilities by addressing a wide range of potential threats by bad actors.

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ACA & PaintCare Submit Universal Waste Petition to EPA

In this petition to U.S. EPA, ACA and PaintCare request that that paint wastes be designated “universal waste” under 40 CFR Section 273. This rulemaking petition formally requests EPA to consider adding paint wastes to the federal universal waste rule. Although paint wastes are not currently on the federal universal waste rule, several states have implemented state-level universal waste rules to include paint wastes. Including paint wastes under the federal universal waste rule would not only ease the regulatory burden experienced by paint manufacturers, paint retailers, paint haulers, and paint recyclers by streamlining management standards, but also promote diverting these wastes from solid landfills.

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