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 29 percent reduction in emissions of nitrogen oxide (NOx) and 53 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 National Ambient Air Quality Standard (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 should implement the 2015 Ozone NAAQS in a flexible manner that allows states to take into account future emission improvements from current programs and make adjustments for contributions from background sources.
- When EPA examines the weight of new evidence for revising a NAAQS, it should carefully examine the scientific uncertainties and potential confounders at lower exposure levels in published health effects studies.
- 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 on how biogenic carbon is treated in the Clean Power Plan as well as air permitting programs.
- As EPA assesses the need for further regulation of pulp mills, it should acknowledge the significant air quality improvements already achieved with over a billion dollars in control investments that mitigated any health risks.
- The agency should allow states to submit implementation plans for startup, shutdowns and malfunctions that rely on flexible work practices and site-specific approaches incorporated in a mill's Title V permit.