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 and 53 percent for sulfur dioxide 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 our business is unsustainable.
AF&PA members are working with the administration, Congress, states and other stakeholders to achieve a sustainable regulatory path for the future. In particular, AF&PA recommends that EPA take the following actions:
- Quickly revise select Boiler MACT emission limits as required by the court using its existing database so they are achievable and affordable.
- Defer further tightening of National Ambient Air Quality Standards, absent compelling new health effects evidence, to allow existing emission reduction programs to take full effect and allow states and industry the time to meet current standards.
- Reduce the number of mill projects that trigger New Source Review (NSR) by changing NSR rules for estimating emissions including decoupling unrelated projects. Examining Agency guidance that can be updated to allow more rapid investments to enhance manufacturing competitiveness.
- Adopt Prevention of Significant Deterioration policies that allow use of more realistic emissions data and modeling tools to replace decades-old approaches. Current overly conservative modeling tools and regulatory assumptions create permitting gridlock and halt needed facility expansions. Projects with limited impacts and using best controls should proceed without unnecessary and burdensome modeling requirements.
- Work rapidly to adopt regulations consistent with the FY 2017 Omnibus Appropriations bill section on “Policies relating to Biomass Energy” to give the paper and wood products industry certainty on how biogenic carbon is treated in federal regulations and air permitting programs.
- Decline to define unavoidable startups, shutdowns and malfunctions (SSM) events as violations of the Clean Air Act, but rather set policies that encourage protection of workers and equipment. The agency should allow states to adopt SSM programs that rely on flexible work practices, SSM plans and site-specific approaches.
- Acknowledge the significant air quality improvements already achieved with over one- billion-dollars-worth of control investments as the agency assesses the need for further regulation of pulp mills. Use the best technologies to mitigate health risks.