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 businesses. 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. In addition, New Source Review (NSR) requirements should be updated so projects that reduce mill emissions or are otherwise minor avoid the burdensome and time consuming NSR process.
- EPA should defer further tightening of NAAQS unless there are proven and significant health benefits. Industry and states need time to implement the current NAAQS 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 assessing emission reductions and remaining risks, and evaluating work practice standards and compliance costs. Compliance with the 2004 MACT and reduced emissions from resin systems have significantly reduced mill environmental footprints.
- Congress has enacted legislation directing EPA, the U.S. Department of Agriculture and Department of Energy to develop straightforward policies that reflect the carbon-neutrality of forest-derived bioenergy. EPA should ensure that biogenic CO2 receives this recognition.
- The agency should modify its start-up, shutdown and malfunction (SSM) policies including the SSM SIP Call to protect the safety of workers and mill equipment and not specify unavoidable events as violations.