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AF&PA Applauds EPA for “Begin Actual Construction” Air Permitting Guidance

CONTACT: Lindsay Murphy/Tim Ebner
(202) 463-2436,

WASHINGTON – American Forest & Paper Association (AF&PA) President and CEO Heidi Brock issued the following statement regarding the Environmental Protection Agency’s (EPA) issuance of “Begin Actual Construction” draft air guidance policy, which will now allow significant construction activity to start parts of a multi-faceted project unrelated to any equipment that has emissions.


“This Environmental Protection Agency (EPA) air guidance takes a welcome step toward recognizing the need for flexibility and common sense in the air permitting process for new construction and site preparation activities. EPA’s current restriction of virtually all such work in advance of obtaining a New Source Review (NSR) permit prevents companies from moving forward, even with non-emitting portions of a project. Under the new policy, more construction and site preparation activities will be allowed prior to obtaining major or minor NSR permits. Ultimately, projects, particularly those in colder climates with a limited construction season, can be completed faster to meet customer needs while at the same time ensuring that any emitting equipment’s air impacts are fully evaluated. In this draft guidance, EPA is adopting a revised interpretation that is more consistent with the regulatory text. We believe this approach allows for both air permitting compliance while also allowing significant investments to move forward that do not impact air quality.”



The American Forest & Paper Association (AF&PA) serves to advance U.S. paper and wood products manufacturers through fact-based public policy and marketplace advocacy. The forest products industry is circular by nature. AF&PA member companies make essential products from renewable and recyclable resources, generate renewable bioenergy and are committed to continuous improvement through the industry’s sustainability initiative —Better Practices, Better Planet 2030: Sustainable Products for a Sustainable Future. The forest products industry accounts for approximately 5% of the total U.S. manufacturing GDP, manufactures about $350 billion in products annually and employs about 925,000 people. The industry meets a payroll of about $65 billion annually and is among the top 10 manufacturing sector employers in 43 states. Visit AF&PA online at or follow us on Twitter @ForestandPaper