"New government regulations that threaten to increase the cost of manufacturing without taking into account the economic, social, and environmental contributions provided by our industry should be avoided. We already face additional capital costs of roughly $14 billion from recent and upcoming Clean Air Act rules.
"Paper and wood products manufacturers have taken voluntary actions to improve the sustainability of the industry and the planet. We have improved our energy efficiency by 8.1 percent since 2005 and are on track to reduce our greenhouse gas emissions by 15 percent. Further, by recovering over 65 percent of the paper consumed in America for recycling, we are helping to reduce methane emissions.
"Our industry's investments in highly-efficient biomass energy also reduce greenhouse gas emissions by displacing fossil fuels. On average, about two-thirds of our energy comes from carbon neutral biomass energy, and our products help create market demand to keep land in forests that sequester carbon rather than development.
"EPA's upcoming framework and regulations on biogenic carbon will provide an excellent opportunity for the agency to recognize the positive contributions of paper and wood products manufacturers to sustainability."