Recognized by EPA as the industry's voice, AWC's Environmental Regulation Program engages federal and state government agencies to provide credible data and policy recommendations that ensure the wood products industry's interests are understood and respected and if necessary, advocated in litigation. The industry's unified engagement in the Environmental Regulation Program has been the key to its success over the past decade. In addition, AWC's strong relationships on the Hill provide leverage and oversight of EPA to ensure more balanced policies.

Over the past decade the American Wood Council has been very effective in shaping regulatory policies in the wood products industry. With a new wave of regulations under development by EPA, wood products companies face the potential for more than $2 billion in new regulatory costs in coming years. In 2013, EPA tightened its MACT standards for boilers as well as established which materials are allowed to be burned as fuels and which materials are considered wastes and make the combustion unit an "incinerator" if burned. After extensive data sharing and communications with EPA, the resulting rules generally are achievable, recognized the importance of biomass fuels, and acknowledge more compliance time may be needed in certain cases.

This has led to:

• Limited obligations on boilers at smaller mills and reduced costs for meeting emission limits for biomass boilers;
• Persuading EPA to revise select Boiler MACT implementation provisions governing startup and shutdown, including use of clean dry biomass;
• Classification of resinated wood, processed construction and demolition debris, and other biomass residuals as non-waste fuels so they can be burned in mill boilers;
• Securing 260 letters to EPA from political officials raising concerns that the proposed Boiler MACT would put jobs at risk and harm the economy;
• Favorable reception at EPA of recommended work practices for proposed new lumber kiln regulations;
• Greater focus by EPA on the challenges of air permitting given tighter NAAQS including issuing guidance that allows favorable adjustment to model inputs for PM and NOx emissions;
• Limiting the tightening of the ozone NAAQS to largely miss the wood products sector;
• Education of key EPA officials and staff, including political, scientific/technical, regulatory and legal staff, on the carbon neutrality of biomass residuals used for energy by the wood products manufacturing industry;
• Providing industry input to OSHA and other governmental entities that engage in rulemaking pertaining to workplace safety;
• Coordinating industry input to private organizations, such as the National Fire Protection Association (NFPA), that help establish consensus standards that influence workplace safety procedures.

Emerging Issues

EPA also is in the process of updating the 2004 Wood MACT (Plywood and Composite Wood Products) rule, brought on by a 2007 court decision that remanded parts of EPA's 2004 rules for two dozen emission units and obligated under a separate court order to evaluate any post-MACT health risks and control technology changes by June 30, 2020. The original MACT resulted in a 90% reduction of regulated emissions which cost the industry hundreds of millions of dollars to meet plus added annual operating costs.  EPA has gathered significant information from the wood products industry in anticipation of the upcoming MACT and Risk and Technology Review (RTR) rulemakings which are expected to include:

• A reassessment of emission controls for dryers and presses; a residual risk review where EPA must determine if unacceptable public health risks remain after the 2004 MACT's implementation; and a consideration of work practices in lieu of numeric standards where emissions are hard to measure or capture for lumber kilns, formers, blenders, saws and several other pieces of process equipment. Depending on the results of its analysis and regulatory approaches taken, this rulemaking could impose modest new costs or add significant new financial obligations on the wood product sector.

EPA also is on a regulatory treadmill to review and potential revise its six National Ambient Air Quality Standards (NAAQS) that cover particulate matter and ozone over the next several years. States, Congress, and even EPA are aware that science does not change so quickly and that the constant ratcheting creates significant business uncertainly in a globally competitive marketplace.  Conducting better scientific research on health effects at current lower levels and improving the standard setting framework are needed.

EPA is looking to AWC for leadership in developing a unified industry strategy with allied groups for these environmental issues. That unity will be essential to our success and to help prevent environmental opponents from exploiting differences within the industry to weaken our advocacy and see the most stringent possible regulations imposed.

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