Clean Air Regulations
The forest products industry has met many costly regulatory challenges over the years, spending billions of dollars as part of its environmental stewardship. Those investments have led to major improvements in air quality, including a 23 percent reduction in emissions of nitrogen oxide (NOx) and 42 percent for sulfur dioxide (SO2) by our pulp and paper facilities since 2000. Unfortunately, the industry faces challenges from two new rules recently released as well as further regulatory proposals – particularly driven by lawsuits or petitions under the Clean Air Act – that together could impose on the order of $14 billion in new capital obligations on the industry during the next three to 10 years.
This challenge comes when the U.S. economy is struggling to add jobs and growth. A 2011 study of the impacts of several major upcoming air regulations found that 18 percent of the primary pulp and paper industry workforce was at risk for job loss and quadruple that number factoring in associated supplier and downstream industries. These job losses would result in billions in reduced wages and lost state, local, and federal taxes.
To address this challenge, AF&PA stands ready to work with EPA, the administration, Congress, states, and other stakeholders to achieve a sustainable regulatory path for the future, including:
- a cost effective approach to mandatory obligations such as Pulp and Paper Residual Risk and Technology Review (RTR) and Wood Maximum Achievable Control Technology (MACT) , working with the inherent flexibility of the statute;
- deferring action on discretionary rules;
- working with states to grant an extra year to comply with the Boiler MACT requirements where justified by significant investments or other potential bottlenecks in implementation;
- EPA listing of additional biomass materials as non-waste fuels and addressing implementation issues identified in the reconsideration petition;
- a practical approach to the development and implementation of National Ambient Air Quality Standards (NAAQS) programs for ozone, particulate matter (PM), nitrogen oxide (NOx), and sulfur dioxide (SO2) that recognize scientific uncertainties, limitations of monitoring data, and use realistic air quality models so that projects can proceed to allow mills to stay competitive;
- a greenhouse gas regulation that maintains the carbon-neutrality of biomass; and
- encouraging continued environmental progress in a regulatory environment that fosters the sustainability of the forest products industry.