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NTMA/PMA One Voice

Domestic Small and Medium Sized Manufacturing (SMM)

Policy Recommendations



Guiding Principle for a Domestic Small and Medium Manufacturing Strategy



The U.S. needs a vibrant, competitive small and medium manufacturing capability in order

to:

• create family sustaining jobs;

• promote innovation;

• drive economic growth, and;

• provide for our national security.



We are pleased that President Obama is placing a high public profile on manufacturing and

are encouraged that the Administration recognizes the need to develop federal policy and

programs to help US manufacturers, both small and large. It is more important than ever that

the federal government and industry work together to develop an industrial strategy

designed to build and grow a sustainable domestic manufacturing sector that can protect our

national security and strengthen our economy now and into the future. In order to succeed,

these policies must encourage domestic manufacturing, incentivize the return of offshore

jobs, and level the domestic and international playing field that has seen so many American

jobs and businesses disappear or go offshore.



The U.S. metalworking industry is fundamental to our country’s economy and central to

strengthening our domestic defense industrial base. Our industry produces components

found in over 90 percent of U.S. manufactured goods and equipment, including a wide

variety of energy-saving and renewable energy products. In fact, it supports the viability of

nearly every key domestic industry sector ranging from agricultural and mining, energy, and

transportation, to aerospace, medical devices, electronics, national defense, and homeland

security. Oftentimes, our products are not readily identified since our contribution, though

essential, is often internal, part of an assembly or good and frequently under the cover of a

machine.



A modern globally competitive economy cannot exist without metalworking. Without the

diverse metalworking sectors, we could not defend this nation, would not have solar panels,

wind turbines, lightweight vehicle parts, water efficient plumbing products or energy-

efficient appliances, among many others. The majority of our industry is comprised of

small and medium-sized firms; many of which are still family-owned.



U.S. manufacturers pay between 17 and 31 percent more in nonproduction costs than the

nation’s nine largest trading partners, according to published reports.1 Rather than support

our manufacturing sector, historically, the government can often serve as the largest

impediment to our competitiveness in the global marketplace, particularly for the 98% of



1

The Manufacturing Institute and the Manufacturers Alliance/MAP, "An Update on Structural Cost Pressures

Facing U.S. Manufacturers," 2008.

Domestic SMM Policy





manufacturers classified as small businesses. While some positive programs exist, much of

this global disadvantage is due to government-imposed costs and policies.



Foundation of a Domestic Small and Medium Manufacturing Strategy



Access to Credit

Manufacturers, especially in the metalworking industries, rely on credit for working capital.

They use this to buy supplies and meet payroll in advance of payment by their customers —

typically a lag time of up to 120 days. In the current economic environment, traditional

lenders are not lending to manufacturers. Automotive suppliers, in particular, find it near

impossible to obtain adequate and timely credit. An October survey by the Precision

Metalforming Association and National Tooling and Machining Association found that 66%

of SMMs in the metalworking industries report problems accessing credit to finance capital

and 68% anticipate difficulty accessing credit when the economy begins to grow. Opening

access to credit for SMMs will prevent further disruption in the manufacturing supply chain

and is critical to investing in new manufacturing technologies and exploring new energy

markets, but new banking regulations are restricting banks from lending even to some of the

most credit-worthy SMMs.



We recommend that the federal government:

• establish a public-private program to facilitate loans to SMMs. Private Sector banks

would provide loans to temporarily impaired SMMs who meet reasonable criteria

for credit worthiness and the federal government will guarantee the loans.

o If an SMM can satisfy such criteria, a requirement for a personal guarantee

shall be waived. A loan could still be provided to a SMM that cannot satisfy

all criteria so long as it can demonstrate sufficient collateral (including work

in process, inventory, and plant and equipment).

• should temporarily change loan criteria for existing federal loan programs, such as

the Small Business Administration’s 7(a) loan program, away from cash flow toward

other reliable criteria more in tune these economic times. Despite an increase in

government guarantees and loan limits, the emphasis on cash flow excludes many

small manufacturers from participating during this economic crisis. In addition, a

personal guarantee is required for a Subchapter S family-owned small business, a

mandate not placed on traditional C Corporations and their shareholders.



Taxes

In order to strengthen the competitiveness of SMMs, we need tax policies that encourage

investment and eliminate tax disadvantages. For example, the corporate tax rate in the U.S.

is 8% higher than our nine largest trading partners (tax rate in China is 15% lower). Sole

proprietorships and other “pass-through” entities, such as S Corps and LLCs account for

72% of all small businesses in the U.S.2 Due to their corporate structure, taxes are paid by

the owners at individual rates.



Furthermore, manufacturing drives innovation by conducting nearly half of all research and

development and creating the bulk of technology in the nation.

2

IRS Statistics of Income - 2004.

Domestic SMM Policy









We need a federal policy that:



• Reduces the federal taxes paid by businesses to make U.S. manufacturers more

competitive globally. The federal government should recognize that a tax increase on

those who report higher incomes in the top two brackets is a direct tax increase on

SMMs and reduces their ability to reinvest in their employees and facility.

• Supports tax incentives that encourage investment in U.S. manufacturing facilities,

in new manufacturing technologies, and foster a healthy manufacturing sector, such

as a:

o Domestic Manufacturing Credit,

o Permanent the Research and Development Tax Credit;

o Extended 50% Bonus Depreciation;

o Enhanced Section 179 Expensing;

o Extended 5-year Net Operating Loss (NOL) Carryback; and.

o Continuation of Last-In-First-Out (LIFO) accounting.



Energy

The industrial sector uses more than 30 percent of U.S. energy and is responsible for nearly

30 percent of U.S. carbon emissions. Increased energy costs combined with fewer domestic

sources of raw materials reduce the global competitiveness of domestic SMMs. The

Administration should not support energy legislation that will substantially increase those

costs and further limit resources.



Federal energy programs intended to foster new energy efficient technologies, such as the

Department of Energy (DOE) Advanced Technology Vehicles Manufacturing (ATVM)

Loan Program (the small business set aside grant has yet to receive a federal appropriation)

and the DOE/Treasury Manufacturing Tax Credit (MTC), are unavailable to most SMMs,

particularly those in the lower tiers of the production chain.



Funding for federal manufacturing programs has fallen dramatically over the past 15 years.

While we applaud the Administration's commitment to the Technology Innovation Program

and other programs at NIST and U.S. Department of Energy (DOE) more must be done to

improve the public private partnership.



The federal government can improve the energy efficiency of SMMs by:



• encouraging development and implementation of new technologies without taxing

energy intense industries;

• ensuring that energy programs are available to all SMMs, including those in the

lower tiers of the production chain, and streamline their application process;

• providing more resources and funding for the Manufacturing Energy Consumption

Survey issued by the Energy Information Administration (due to budget cuts, the

sample size is shrinking and the report is only released every four years making it

difficult to obtain timely energy data);

Domestic SMM Policy





• increasing funding for new and existing research programs, such as DOE’s Industrial

Technologies Program (ITP), that encourage rapid development of new energy

manufacturing technologies and energy efficiency processes if the U.S. is to compete

with countries like China3 and Germany.4

• the federal government should promote the clean development of domestic energy

sources, thereby significantly reducing the portion of the U.S. trade deficit that is

caused by our dependency on imported carbon units.



Trade

Trade can be a significant engine of growth for SMMs with proper enforcement and open

access to foreign markets. We applaud the Administration’s efforts to promote trade and

enhance global competitiveness, and we support the priorities for improving trade set forth

by Commerce Secretary Locke this summer. However, we must keep in mind that leveling

the global playing field for American manufacturers starts at home.



The Administration should:



• enforce trade agreements and correct currency imbalances and manipulation by our

trading partners in order to ensure that U.S. manufactured products are competitive

domestically and worldwide;

• encourage the production and consumption of domestic sources for our nation's

defense;

• provide additional resources to the Census Bureau, in order to obtain more in-depth

information from the primary source of economic information - the Census of

Manufacturing and the Annual Survey of Manufacturing (budget cuts have impacted

the depth and timing in which the data is released);

• set aside funds to ensure that NAICS and Harmonized Tariff Schedule (HTS) codes

correspond so that both policymakers and SMMs have the data they need [Many

products made by industries within manufacturing NAICS 31-33 do not either

correspond to a HTS number or NAICS code, without which the federal government

cannot determine the level of imports and exports of those products.]

• Provide a monthly sector-by-sector analysis of domestic manufacturing that reports

how domestic and international policy is effecting manufacturing sectors to better

identify policies that reduce U.S. competitiveness.



Workforce Recruitment, Training, Retention

A well-trained and skilled workforce is essential to the future success of manufacturing in

America. It is the driver of innovation. SMMs in particular maintain excellent relationships

with their workers, often employing multiple generations of the same family, and paying

excellent wages. However, SMMs often lack an organized recruitment base enjoyed by

larger corporations in various industries.





3

China produces 40% of the world's solar panels (Wall Street Journal, "Applied Materials Looks to China for

Solar's Future," Sept. 25, 2009.)

4

With more than 50,000 new jobs, the renewable energy industry in Germany is now second only to its auto

industry (New York Times, Thomas Friedman Op-Ed "Have a Nice Day," Sept. 15, 2009.)

Domestic SMM Policy





In regards to ensuring a skilled manufacturing workforce, we recommend that the:



• Federal, State, and Local Governments should establish public-private partnerships

that coordinate an industrial strategy with K-12 schools, community and technical

colleges, and SMMs and trade groups.

• The federal government should provide funding for apprenticeship programs aimed

at jobs in the metalworking industry, as part of its effort to strengthen community

colleges and vocational institutions.

• The federal government should establish federal grants directly to non-profit

foundations and educational institutions for workforce recruitment, training, and

retention including youth outreach.



We must focus on our strengths. Potato chips or microchips, green jobs or blue jobs, we

need them all, but there will be no lasting growth in America until there is trade reform that

unleashes the genuine strength of industries like ours to compete for our fair share of the

global economy, including here at home.



The U.S. must focus on a significant re-investment in the manufacturing industry in order to

drive critical innovation, develop the skills of the next generation of workers, and effect

policies that sustain a favorable business climate so that manufacturing jobs remain in this

country.



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