Original Date: 02/23/1998
Revision Date: 01/18/2007
Best Practice : Legislative and Regulatory Involvement
With California being one of the most regulated and environmentally restricted parts of the country for manufacturers, Northrop Grumman learned early on that the regulatory agencies did not have a good understanding of the aerospace industry. As a result, the company has taken an active role in the environmental regulatory and rule making process for many years.
As one of the largest manufacturers in the southern California region, Northrop Grumman found that proactive involvement is essential in the environmental regulatory and rule making process. This region is one of the most regulated and environmentally restrictive parts of the country for manufacturers. Northrop Grumman learned early on that the regulatory agencies did not have a good understanding of the aerospace industry, and thus the company has taken an active role in rule development for many years. Only by companies working with regulators can rules be adopted that achieve the intended goals, but not be overly burdensome.
Northrop Grumman has a broad array of regulatory agencies which it must satisfy in addition to the federal EPA. California state regulatory agencies include the California EPA; the Air Resources Board; the Department of Toxic Substance Control; the Office of Health Hazard Assessment; the Water Resources Control Board; and the Integrated Waste Management Board. Local environmental agencies include South Coast Air Quality Management District (SCAQMD); the Antelope Valley Air Pollution Control District; the Mojave Desert Air Quality Management District; the Certified Unified Permitting Agency; and regional water quality control boards. In general, the regulatory requirements of the state, regional, and local agencies are more stringent than federal EPA requirements (e.g., regional regulations on chromium are 12 times more stringent than federal EPA regulations. Rather than stand along against this formidable array of regulatory agencies, Northrop Grumman formed alliances and partnerships with various industry groups. The company is a member of the Southern California Air Quality Alliance which is a unit of the California Manufacturers Association. Another is the Regulatory Flexibility Group, a diverse group of about 14 major manufacturers in the region that is active in influencing regional regulatory requirements and issues. Northrop Grumman is also an active member of the California Aerospace Environmental Association, and participates on various industry ad hoc committees that are formed to work on specific regulatory implementation issues. The company also retains an environmental lobbying firm in Sacramento to give it a voice in shaping proposed legislation affecting the aerospace industry in California.
These alliances and relationships have helped the company deal with a variety of issues including adoption of the Regional Clean Air Incentives Market (RECLAIM) rules; air toxic control regulations for new and existing sources; new aerospace coatings and solvents rules; and the new federal Title V Operating Permits Program for emitting and potentially emitting sources. In the case of the RECLAIM rules, all of the industry groups in which Northrop Grumman participates took a proactive approach to these rules, primarily dealing with the combustion of fuels. Group leaders from the various organizations actively worked with top-level SCAQMD management. Personnel from Northrop Grumman participated in the agency rule-making process including advisory committees, working groups, and public workshops. Northrop Grumman and industry group representatives met regularly with rule- making staff members to tour facilities, provide technical data, participate in pilot programs, and review and comment on proposed rule drafts. This approach helped Northrop Grumman win realistic NOx and SOx allocations based on past productivity and equipment requirements for individual facilities. In addition, the company successfully communicated to the regulatory agencies that proposed volatile organic compound (VOC) requirements were too low and had excessively burdensome reporting requirements. Other accomplishments included extending the compliance date for reducing the VOC content of 250°F cure adhesive bonding primer from 805 to 250 grams per liter in light of the fact that compliant primers were not available.
Many new challenges face Northrop Grumman and the aerospace industry in the coming years. By taking a proactive approach, working with the regulatory agencies, and educating regulators about unique aerospace requirements and concerns, Northrop Grumman developed a very effective approach to protecting the environment responsibly while maintaining its competitive position and the quality of its products.
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