Members’ input drives advocacy successes
2020 saw the publication of a new U.S. Department of Energy (DOE) Process Rule, as well as a final rule streamlining test waiver procedure processes. Both of these important rules, and more, were informed by comments NAFEM submitted on behalf of its members.
“The association and its members worked very hard for the past five years to get where we are today,” said Jeff Longsworth, NAFEM legal counsel, Barnes & Thornburg. “For example, many of the revisions outlined in the new Process Rule stem back, in part, to some of the issues NAFEM raised in its commercial refrigeration equipment litigation in 2014 and were reiterated and expanded upon during a regulatory roundtable meeting NAFEM arranged with DOE legal counsel in 2017.”
These efforts to advocate on behalf of the industry work best when members get involved.
“We want to balance the impact of regulation and legislation to give our members a level playing field,” said Charlie Souhrada, CFSP, NAFEM’s vice president, regulatory & technical affairs. “Through our combined efforts, companies of all sizes have a seat at the table, which is why member input to proposed rules and laws is so important.”
NAFEM staff and B&T constantly review the Federal Register, agency press releases and regulatory announcements for issues, including pending regulations that might impact members. Also, members sometimes learn of issues before they are announced to the public and alert NAFEM. In any event, NAFEM attempts to filter through the issues and then seeks member input on those that are important through monthly calls, emails or other communications.
“We hope that such solicitations result in a member sending a brief email outlining the impact of the proposed rule on their business,” said Longsworth. “Then, we’ll schedule a quick call to better understand the member’s perspective. This also is a good time to discuss alternatives we can include in NAFEM’s comments. Once we draft the comments, we then send them for review before submitting to the agency. Our goal is to obtain valuable member input while also trying to make the process easy and efficient for members.”
“Having a say in advocacy-related issues is one of the key reasons members belong to NAFEM,” said Souhrada. “Member input is critical to developing the right influencing strategy. By combining members’ manufacturing expertise with the association’s advocacy experience, we can drive powerful outcomes for the industry.”
“Of course, it all starts with member engagement on issues that are important to them, which we regularly seek and always appreciate,” said Longsworth.