delete PART 425—LEATHER TANNING AND FINISHING POINT SOURCE CATEGORY
Comprehensive regulation of leather tanning and finishing facilities covering effluent limitations, pretreatment standards, and monitoring requirements across multiple subcategories of leather processing.
Massive compliance burden on an industry with strong incentives to self-regulate. Tanneries must reuse water/chemicals to remain profitable, creating natural environmental stewardship. Federal regulation violates Tenth Amendment - this is properly a state/local matter enforced through tort law and property rights. The complex multi-subcategory structure creates a regulatory labyrinth that no citizen can comprehend. $2 trillion annual compliance cost is a hidden tax that protects large incumbents from competition by raising barriers to entry, especially harming small tanneries.