EPA Air Regulations

The paper and wood products manufacturing 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 new and existing regulations – driven by lawsuits under the Clean Air Act – that together could impose more than $10 billion in new capital obligations on the industry over the next 10 years. The cumulative burden being imposed on business is unsustainable.

AF&PA members are working with EPA, the administration, Congress, states, and other stakeholders to
achieve a sustainable regulatory path for the future.

• The proposed tightening of the ozone National Ambient Air Quality Standard (NAAQS) could put five
times more paper and wood product mills at risk and thwart job growth. EPA should acknowledge
the significant scientific uncertainties and ongoing improvements in air quality and retain the current
standard in the Oct. 1, 2015 final rule.

• The 2013 NAAQS for particulate matter, as well as other NAAQS, threaten 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.

• EPA’s revised framework to account for biogenic carbon is a step in the right direction for recognizing
the carbon benefits of certain manufacturing residuals, but the forest products industry needs certainty
that all types of bioenergy it produces and uses is carbon neutral.

• EPA should toll the compliance deadline for Boiler MACT given the regulatory and litigation delays
that have created substantial business uncertainty around compliance investments. States should
grant one-year compliance extensions to mills that need additional time.

• The agency should finalize the list of additional biomass materials as non-waste fuels without
restrictions and solve implementation problems identified in its reconsideration proposal, such as
start-up and shutdown requirements, by quickly amending the current regulations.