Future Relies on Sustainable Air Regulations
The paper and wood products manufacturing industry has spent billions of dollars as part of its environmental stewardship to comply with regulations. These expenditures, in part, have led to a 36 percent drop in emissions of nitrogen oxide and a 73 percent drop for sulfur dioxide in paper and pulp facilities since 2000. Unfortunately, despite these and other emission improvements, the Clean Air Act could impose even stricter requirements with billions in new investment obligations over the next 10 years. The combined financial hardship these regulations impose on the industry is unsustainable.
AF&PA members are working with the administration, Congress, states and other stakeholders to achieve a sustainable regulatory path. AF&PA recommends that EPA take the following actions:
- Acknowledge the significant air quality improvements already achieved by the industry.
- Revise select Boiler MACT emissions limits, as required by the court, using existing data to ensure the process is swift and regulation is affordable.
- Refrain from tightening National Ambient Air Quality Standards to allow existing programs to take full effect and give states and the industry time to meet current standards.
- Reduce the number of mill projects that trigger New Source Review (NSR) by changing NSR rules for estimating emissions.
- Adopt policies that allow use of more realistic data and modeling tools in order to speed up building projects with limited impacts.
Allow for unavoidable startups, shutdowns and malfunctions (SSM) events
to occur without violation of the Clean Air Act, and instead allow states to regulate SSM events in a way specific to each site and pursuant to worker safety.