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 expense 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), the administration, Congress, states and other stakeholders to achieve reasonable regulations that protect the environment and business. What is needed?
- EPA should respond to the 2016 D.C. Circuit Court decision on Boiler MACT by setting reasonable emissions limits that reflect the variability of the best performing boilers by type 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.
- The recent revisions to the Ozone NAAQS should be implemented in ways that mitigate costs by accounting for upcoming air quality improvements from existing requirements. EPA should not require ozone modeling for sources until the tools are validated and well understood.
- As EPA undertakes its risk and technology reviews for the Plywood and Composite Panel MACT, it should work closely with AWC and the industry on information collections and assessments of emissions, work practices and compliance costs. Compliance with the 2004 MACT and reduced emissions resin production 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 residuals such as bark and sawdust. Under the Clean Power Plan, states should endorse biomass as a carbon neutral fuel in their implementation plans.