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American Wood Council

The wood products industry has met many costly regulatory challenges over the years, spending hundreds of millions of dollars as part of its efforts to protect the environment. The industry now faces additional challenges and expenses from recently released and pending regulatory proposals – driven by lawsuits or petitions under the Clean Air Act – that together could impose billions of dollars in new capital obligations over the next 10 years.

AWC and its members are working with the U.S. Environmental Protection Agency (EPA), administration, Congress, states and other stakeholders to achieve reasonable regulations that protect the environment and business. Our recommendations are:

  • EPA should quickly revise limited parts of the 2013 Boiler Maximum Achievable Control Technology (MACT) rules as required by the 2016 court decision. It should rely on the existing record and set reasonable emissions limits that reflect the variability of the best performing boilers and encourage use of carbon neutral, renewable biomass as a sustainable and affordable fuel.
  • The 2013 National Ambient Air Quality Standard (NAAQS) for particulate matter, as well as other NAAQS, threaten to create permitting gridlock and halt needed facility improvements unless EPA adopts more flexible policies and allows use of more realistic emissions and modeling data.
  • ‚ÄčEPA should defer further tightening of NAAQS unless there are proven and significant health benefits. Industry and states need time to implement current programs which will significantly reduce emissions in the years ahead. A ten-year NAAQS review cycle would create greater business certainty and allow time for more measured, scientific assessments.  
  • As EPA undertakes its risk and technology reviews for the Plywood and Composite Wood Product MACT, it should work closely with AWC and the industry on minimizing burdens from information collections, assessing emission reductions, and evaluating work practices and compliance costs. Compliance with the 2004 MACT and reduced emissions resin systems have significantly reduced mill environmental footprints.
  • EPA’s final Biogenic CO2 Accounting Framework and greenhouse gas regulations should maintain the carbon neutrality of biomass, particularly for residuals such as bark and sawdust. EPA should endorse biomass as a carbon neutral fuel in their GHG Tailoring Rule that sets GHG permitting thresholds.
  • The agency should modify its start-up, shutdown and malfunctions (SSM) policies to protect the safety of workers and mill equipment and not define unavoidable events as violations. EPA should approve state SSM implementation plans that rely on flexible work practices and site-specific approaches incorporated in a mill’s Title V permit.
American Wood Council
222 Catoctin Circle SE, Suite 201
Leesburg, VA 20175

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