"While we need to study the rule in more depth, we will be looking for improvements from the December 2011 re-proposed rules on the use of biomass residuals as fuels, compliance time, and achievability," said AF&PA President and CEO Donna Harman. "However, approximately $3 billion in capital spending will be necessary to comply. This is a significant investment for an industry still recovering from the economic downturn, especially in light of the growing cumulative regulatory burden we face.
"We appreciate the amount of time and energy that the EPA, many members of Congress, governors, and other stakeholders have taken to fully understand our concerns related to this final rulemaking. Throughout this process, we maintained an open and healthy dialogue with EPA and provided extensive data and comments in the hope that rules would be developed that are achievable and affordable for our industry."
It will take weeks to fully understand the rules' implications; however, a preliminary review reveals progress on the industry's three primary concerns: achievability of emissions limits, listing of biomass residuals as fuels, and adequate compliance time.
Technical Achievability:Existing technology and control strategies should allow most facilities to meet the emission limits outlined in the rules.
Compliance Time:EPA included language in the preamble that urges states to grant a fourth year to comply up front under certain circumstances, which many will likely do.
Fuel Listings:EPA is expecting to amend the list of non-waste fuels (which already includes wastewater treatment residuals, resinated wood, and tire-derived fuels) to include paper recycling residuals, processed construction and demolition wood, and railroad ties. AF&PA will work with EPA to ensure swift action.
The American Forest & Paper Association is the national trade association of the forest products industry, representing pulp, paper, packaging and wood products manufacturers, and forest landowners. Our companies make products essential for everyday life from renewable and recyclable resources that sustain the environment. The forest products industry accounts for approximately 5 percent of the total U.S. manufacturing GDP. Industry companies produce about $190 billion in products annually and employ nearly 900,000 men and women, exceeding employment levels in the automotive, chemicals and plastics industries. The industry meets a payroll of approximately $50 billion annually and is among the top 10 manufacturing sector employers in 47 states. Visit AF&PA online at www.afandpa.org.