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.
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.
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”).
ACA Comments on Colorado's Proposed Producer Responsibility Regulations
ACA submitted comments to the Colorado Department of Public Health and Environment with recommendations on the agency's proposed Producer Responsibility Regulations for plastic packaging under the Solid Waste and Materials Management Program.
ACA, Coalition Submit Comments to EPA on Proposed RCRA Hazardous Constituent Listing of Nine PFAS
ACA was part of the U.S. Chamber of Commerce’s Coalition of Companies, trade associations, and other stakeholders on the U.S. Environmental Protection Agency’s Proposed Rule, Listing of Specific PFAS as Hazardous Constituents.
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.
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.
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.
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.
ACA Supports the Tax Relief for American Families and Workers Act
The Tax Relief for American Families and Workers Act will restore three tax policies vital to workers and America’s future: immediate expensing of domestic R&D expenses, enhanced interest deductibility, and 100% accelerated depreciation.