AWC Supports “Begin Actual Construction” Guidance

Mar 25, 2020

WASHINGTON – American Wood Council (AWC) President and CEO Robert Glowinski issued a statement following the Environmental Protection Agency’s (EPA) release of the draft “Begin Actual Construction” air guidance memo. It clarifies that construction on non-emission elements of a project can begin before obtaining a New Source Review (NSR) permit.

“Wood products manufacturers are continually making capital investments to improve systems and keep them operating properly and efficiently. However, current EPA policy has limited virtually all preparation or construction activities in advance of receiving an NSR permit, even if planned improvements would not affect emissions, such as putting in foundations or utility infrastructure. Today’s guidance means a project can be completed faster while ensuring that air impacts from emitting equipment are still properly evaluated. This is particularly important in states with shorter construction seasons, such as Michigan and Wisconsin, which also have large numbers of wood product manufacturing jobs.”