Biodiversity Policy Engagement Analysis
Biodiversity Lobbying Overview: The National Association of Manufacturers (NAM) appears to have limited top-line messaging on biodiversity loss. NAM’s engagement on biodiversity-related policy has been consistently unsupportive.
Top-line Messaging on Biodiversity Loss: NAM appears to have limited top-line messaging on biodiversity loss. In a May 2019 press release, NAM appeared to acknowledge the science of biodiversity loss, however it has not disclosed any further positions since. In a January 2022 press release, NAM described the need to “reverse damage to the natural world”, but has not clearly supported the need for urgent action to address biodiversity loss. NAM published a position paper in April 2020 in which it described its position on environmental measures and appeared to support a market-based response over government regulation. In July 2023, NAM wrote a letter to members of the Committee on Financial Services in the U.S. House of Representatives that advocated for a US bill that would study and provide policy recommendations to reduce the impact of the EU's Corporate Sustainability Due Diligence Directive (CSDDD) on US businesses.
Engagement with Biodiversity-Related Regulations:NAM has engaged in legislation related to biodiversity loss due to land use change and pollution. NAM published a position paper on its website in April 2020, opposing restrictions on the exploitation of resources of federal lands. NAM has consistently engaged on the Waters of the United States (WOTUS) regulation since 2018. During the Trump administration, NAM published a 2018 annual report in which it advocated for the repeal of the 2015 WOTUS rule. NAM published press releases opposing the Biden administration’s proposal on WOTUS in, December 2022, March 2023 and May 2023. NAM is part of the Waters Advocacy Coalition, which has also advocated against the WOTUS rule. In September 2021, the Waters Advocacy Coalition submitted a comment to the Environmental Protection Association opposing the repeal of the Navigable Waters Protection Rule, which weakened the 2015 Water of the United States Rule. In February 2022, the Waters Advocacy Coalition submitted another comment opposing the Biden Administration's proposed new Water of the United States Rule. In its US Senate Lobbying Disclosures, NAM disclosed engagement on the National Environmental Policy Act (NEPA) in 2022.
NAM has also engaged on policy related to pollution. In a June 2022 press release, NAM advocated against the Environmental Protection Agency’s proposed Water Quality Certification Improvement Rule. In a November 2022 comment, NAM opposed the EPA’s designation of Per- and polyfluoroalkyl substances (PFAS) as hazardous under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). NAM is a signatory of a July 2021 joint letter to Chairman Tonko and Member McKinley, US House of Representatives Subcommittee on Environment and Climate Change, opposing the PFAS Action Act, H.R. 2467. In a December 2021 comment, NAM advocated against the phenol, isopropylated phosphate (3:1) (also known as PIP (3:1)) regulation under Section 6(h) of the Toxic Substances Control Act, not supporting stringent restrictions on the chemicals despite the EPA’s recommendation over its environmental safety. NAM advocated for the EPA to consider voluntary initiatives to prevent plastic pollution, suggesting that restrictive measures could hinder companies' business in a July 2023 comment. In its EU Transparency Register entry, updated in March 2023, NAM disclosed engagement on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH).
Positioning on Statutory Protection of Wildlife:NAM has opposed the statutory protection of wildlife. In a position paper from April 2020, NAM supported “streamlining processes” that could weaken the Endangered Species Act. NAM signed a coalition letter to the Fish and Wildlife Service in May 2022 opposing listing the northern long-eared bat as endangered. In its US Senate Lobbying Disclosures, NAM disclosed engagement on the Endangered Species Act in 2023 and the Migratory Bird Treaty Act in 2021.