Over the last several decades, SSINA members have made major reductions in energy consumption and, accordingly, GHG emissions associated (both directly and indirectly) with the manufacture of specialty steels.
Specialty steel production is necessarily an energy intensive process. SSINA members produce high grade stainless and other specialty steel products by using electricity to melt scrap metal and other raw materials in an electric arc furnace (EAF). Carbon and energy are essential to the production of steel and represent the primary sources of greenhouse gas (GHG) emissions from specialty steel manufacturers. Energy comprises about 10-20 percent of the total cost of specialty steel production.
SSINA members have a proud history of continually exploring ways to become more energy efficient. This makes sense from both an economic and environmental perspective. As a result, over the last several decades, SSINA members have made major reductions in energy consumption and, accordingly, GHG emissions associated (both directly and indirectly) with the manufacture of specialty steels.
The energy-efficient production of specialty steels is only part of the story, however. Perhaps more important is the fact that, as a consequence of their enduring quality, specialty steels help produce more effective and long-lasting products, ultimately resulting in the consumption of fewer natural resources and energy.
As legislators and the public at large debate the need for and potential structure of a GHG regulatory system, SSINA urges consideration of the following:
SSINA supports further research into technological and process improvements to reduce GHG emissions and improve energy efficiency. Only through the development and utilization of technologies that can economically capture or reduce GHG emissions will the domestic specialty steel industry remain vibrant and competitive.
Any program to restrict GHG emissions must be “trade neutral” to prevent market distortions from non-participating countries. Policy must avoid marketplace distortions and not cause a shift in production to less environmentally progressive mills in “developing” countries (that have thoroughly developed steel industries) in order to meet U.S. steel consumption needs. Such a development would have the perverse effect of increasing global GHG and other emissions. SSINA members are among the most energy-efficient producers of specialty steels in the world and have already made substantial reductions in GHGs emitted per ton of steel produced through substantial capital investment in technological and process improvements. This success should not be undermined by shortsightedly imposing mandatory GHG controls that result in providing an unfair competitive advantage to producers in other countries. Imported products should be required to meet the same standards (including with respect to carbon intensity) as domestically produced specialty steel.
Climate change policy needs to recognize the need for a growing U.S. economy. Significant additional reductions in total GHG emissions by specialty steel producers are not possible without substantially reducing the production of specialty steels that are vital to our country’s economy and security. For this reason, SSINA supports emission comparisons based on energy intensity or emissions efficiency (total amount of GHG emissions per amount or value of steel produced). This is the only fair measure of production efficiency.
SSINA believes that sector-based approaches focused on best industry technology practices are the most viable means of achieving substantial improvements in energy-efficiency (and GHG emission reductions) while mitigating potential economic disruptions.Given the importance of electricity to specialty steel production, SSINA supports the electricity generating industry’s initiatives to improve its GHG emissions efficiency. SSINA strongly supports the development of alternative and low- and no-emission means of electricity generation, including increased utilization of nuclear power to facilitate the reduction of GHG emissions.