EPA Air Regulations
The forest products industry met many costly regulatory challenges over the years, spending billions of dollars as part of its environmental stewardship. Those investments 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 recently released as well as expected new regulatory proposals –driven by lawsuits or petitions under the Clean Air Act – that together could impose roughly $14 billion in new capital obligations on the industry during the next three to 10 years.
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.
AF&PA members are working with EPA, the Administration, Congress, states, and other stakeholders to achieve a sustainable regulatory path for the future, including:
- Implementation of the final Boiler MACT rules in a reasonable timeframe. States should grant an extra year to comply, where justified, to allow significant investments or to address other potential bottlenecks in implementation. EPA also should list additional biomass materials as non-waste fuels and solve implementation problems identified in the reconsideration petition.
- The recently adopted National Ambient Air Quality Standard (NAAQS) for particulate matter (PM) threatens to create permitting gridlock and halt needed facility expansions unless EPA adopts more flexible policies and allows use of more realistic emissions and modeling data.
- The upcoming revisions to the ozone NAAQS could more than triple the number of areas in non-attainment, putting five times more forest product mills at risk and thwarting job growth. EPA should acknowledge the significant scientific uncertainties and the continuous improvements in air quality relative to background levels.
- An Accounting Framework and greenhouse gas regulation that maintains the carbon-neutrality of biomass.
- Encouraging continued environmental progress in a regulatory environment that fosters the sustainability of the forest products industry and other manufacturers.