Comments on Proposed EPA Regulations

White Notch ReverseWhite Notch

August 31, 2023

Pittsburgh Works Comments to the EPA on Proposed Amendments to Air Toxics Standards for Coke Ovens Pushing, Quenching, and Battery Stacks; and Coke Oven Batteries

PITTSBURGH – My name is Ken Zapinski, and I am the director of research and public policy for Pittsburgh Works Together, an alliance of organized labor and employers created to protect and advance the industries that are at the foundation of our society, including energy and manufacturing, in order to provide economic opportunities and family-sustaining jobs for all people.

When the Biden Administration is pumping hundreds of billions of dollars into the economy through the Infrastructure bill and other programs, it’s the wrong time to attack an industry critical for building infrastructure and energy facilities those programs call for.

Want to build wind turbines? You need steel. Need high voltage transmission lines to carry power from solar farms? Steel. The facilities to house high-tech chip manufacturing coming back to the U.S. from overseas? Steel.

Coke production is a critical step in the integrated steel production process. We cannot meet all our needs with steel made from recycling scrap in electric arc furnaces. As a matter of national security and maintenance of our advanced economy, we need to retain the ability and skills necessary to turn rocks into steel.

That process has environmental impacts, but it is already highly regulated, and the country’s air and water are cleaner now than they have been at any time since the Industrial Revolution.

According to the EPA’s own estimates, coke facilities present low, acceptable risks with a sufficient margin of safety to protect public health.

Life expectancy is dropping in the U.S. but not because of a public health threat from coke ovens or steel production. They are deaths of despair, from suicide and addiction, much of it driven by economic circumstances and a loss of hope in today’s economy. Unnecessarily burdening the steel production process with increased regulation is an effective way to shut down plants and increase economic hopelessness. That is a public health issue as well.

These proposals are of particular concern in southwestern Pennsylvania as a section of the proposed regulations appears to have been arbitrarily set to specifically target the Clairton coke plant that is part of US Steel’s Mon Valley Works. The Mon Valley Works supports nearly 4,000 direct jobs and contributes close to $5 billion annually to the regional economy.

The coke plant is the linchpin of the operation, and it would be subject to new regulations that are not consistent with the EPA’s own procedures.

Once again, the EPA is overreaching by trying to impose environmental outcomes that have not been proven to be possible using existing technology. By law, the results that the proposed regulations require must be “achievable” both technologically and economically. The burden is on the EPA to demonstrate, with hard data over long operating periods, that the proposed regulations meet that standard.

The agency has not done so.

Showing that one plant on one day for one moment in time can meet a particular emissions profile is not a sufficient basis to tear down an industry that is critical to union workers, to the U.S. economy, the global energy transition, and national defense.

Any amendments made to the existing coke oven regulations should be consistent with the requirements of the Clean Air Act, based on sound science, and consider the costs to implement and operate. Thank you.

Pittsburgh Works News Logo
Join Pittsburgh Works
Enter your email to receive the latest news:


  • This field is for validation purposes and should be left unchanged.

Jeff Nobers | Executive Director |
Ken Zapiniski | Director of Research and Public Policy |
General Inquires:

631 Iron City Drive
Pittsburgh, PA 15205

Pittsburgh Works Together, Inc.
Copyright 2023 - All Rights Reserved
Privacy Policy