Regulatory Relief for Certain Stationary Sources to Promote American Chemical Manufacturing Security

7/17/2025

Proclamations

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Action Summary

Purpose: Support the domestic chemical manufacturing sector to bolster industries vital to energy, national defense, agriculture, health care, and overall economic resilience.
Background: The Environmental Protection Agency’s HON Rule (issued May 16, 2024) imposes new emissions-control requirements on synthetic organic chemical manufacturing facilities, which many argue are excessively burdensome and technologically unfeasible.
Exemption Details: The President exempts certain stationary sources—listed in Annex I—from compliance with aspects of the HON Rule under section 112 of the Clean Air Act for 2 years beyond the original deadlines. During this period, facilities will continue to follow pre-HON Rule standards.
Rationale: Determined that the necessary technology for compliance is not commercially viable and that the exemption is in the nation’s security and economic interests, ensuring supply chain continuity and national preparedness.
Affected Facilities: The exemption applies to a range of chemical manufacturing sites across multiple states as detailed in Annex I, impacting major industry players.

Risks & Considerations

The exemption from the HON Rule for certain chemical manufacturing facilities may lead to increased emissions and environmental concerns, potentially affecting public health and safety. This could result in reputational risks for institutions associated with these industries, including Vanderbilt University if it has partnerships or research initiatives linked to these sectors.
The delay in compliance with the HON Rule may impact the university’s research and educational programs related to environmental science, public health, and chemical engineering, as it may alter the regulatory landscape and the focus of ongoing and future studies.
Vanderbilt University may need to reassess its collaborations with industries affected by this exemption, particularly if these partnerships involve research on emissions control technologies or environmental impact assessments.
The exemption could influence the university’s sustainability goals and initiatives, as it may affect the broader environmental policies and practices within the chemical manufacturing sector.

Impacted Programs

Vanderbilt’s School of Engineering may need to adjust its curriculum and research focus to address the changes in regulatory requirements and the technological challenges faced by the chemical manufacturing industry.
The Vanderbilt Institute for Energy and Environment might experience shifts in research priorities, particularly in areas related to emissions control and environmental policy.
Public Health Programs at Vanderbilt could be impacted by changes in air quality and environmental health standards, necessitating updates to research and community outreach efforts.
The Office of Sustainability may need to consider the broader implications of this exemption on the university’s sustainability initiatives and partnerships with industry stakeholders.

Financial Impact

The exemption may lead to changes in funding opportunities for research related to emissions control and environmental compliance, potentially affecting grant applications and collaborations with federal agencies.
Vanderbilt University might need to explore alternative funding sources or partnerships to support research and educational programs impacted by the regulatory changes in the chemical manufacturing sector.
There could be potential financial implications for the university if it is involved in projects or partnerships with the affected chemical manufacturing facilities, particularly if these projects are tied to compliance with the HON Rule.

Relevance Score: 3 (The exemption presents moderate risks involving compliance and potential impacts on research and partnerships.)

Key Actions

Vanderbilt’s Environmental Science and Engineering Department should evaluate the implications of the regulatory relief on chemical manufacturing and its potential impact on environmental standards. This assessment can guide research initiatives focused on sustainable practices and technologies that align with both regulatory requirements and environmental protection goals.
The Office of Federal Relations should monitor developments in the chemical manufacturing sector and engage with policymakers to advocate for balanced regulations that support both industry growth and environmental sustainability. This engagement can help shape future policies that impact the university’s research and educational programs.
Vanderbilt’s Research Centers could explore partnerships with chemical manufacturers to develop innovative solutions that address compliance challenges while enhancing environmental performance. These collaborations can position Vanderbilt as a leader in advancing sustainable chemical manufacturing technologies.
The School of Law should analyze the legal implications of the exemption and its potential effects on environmental law and policy. This analysis can inform legal education and provide insights into the evolving landscape of environmental regulation.

Opportunities

The regulatory relief presents an opportunity for Vanderbilt’s Engineering School to engage in research and development of new technologies that can help chemical manufacturers meet emissions standards more effectively. By leveraging its expertise in engineering and technology, the school can contribute to the development of innovative solutions that enhance industry compliance and sustainability.
Vanderbilt can capitalize on the focus on national security and economic resilience by developing programs and initiatives that address the intersection of chemical manufacturing, environmental protection, and national defense. This interdisciplinary approach can enhance the university’s reputation and influence in these critical areas.
The emphasis on maintaining a robust domestic chemical industry aligns with Vanderbilt’s commitment to economic development and innovation. The university can develop targeted outreach and support programs for students and researchers interested in careers in chemical manufacturing and related fields.

Relevance Score: 3 (Some adjustments are needed to processes or procedures to align with regulatory changes and capitalize on research opportunities.)

Average Relevance Score: 2

Timeline for Implementation

Compliance deadlines for the listed stationary sources under the HON Rule are extended by 2 years from their originally specified deadlines.

Relevance Score: 1

Impacted Government Organizations

Environmental Protection Agency (EPA): The EPA is directly impacted because it published the HON Rule under the Clean Air Act, which is now subject to a 2‑year exemption for certain stationary sources as described in the proclamation.
Department of Defense (DoD): Although not a regulatory agency in this context, the DoD is relevant due to the national security considerations outlined, linking chemical manufacturing capacity with military readiness and supply chain resilience.
Executive Office of the President: The proclamation itself, issued under presidential authority, directs a change to an existing regulation, impacting interagency oversight and policy coordination across the federal government.

Relevance Score: 2 (Three government organizations are directly or indirectly impacted by this action.)

Responsible Officials

N/A – The proclamation issues a direct exemption for certain facilities without delegating implementation responsibilities to any specific official or agency.

Relevance Score: 1 (Directives affect only the listed facilities, with no specific official-level implementation assigned.)