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.