The Forest Products Industry and the Clean Air Regulatory Challenge Paul R. Noe Vice President for Public Policy American Forest & Paper Association Arkansas Forestry Association Annual Meeting Little Rock, Arkansas September 26, 2012
1. The Forest Products Industry andthe Clean Air Regulatory
Challenge Paul R. Noe Vice President for Public Policy American
Forest & Paper Association Arkansas Forestry Association Annual
Meeting Little Rock, Arkansas September 26, 2012
2. Overview Cumulative Burden of Air Regulations Highlights of
Key Air rules Boiler MACT, etc Carbon Neutrality Need for
Sustainable Regulations 2
3. Forest Products Industry Employment* 000
workers1,7001,6001,5001,4001,3001,2001,1001,000 900 800 1997 1998
1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011
2012 * Includes paper and allied products, wood products, and
logging. Source: Bureau of Labor Statistics
4. Rules, Costs and Timing Issued Final Rule Potential Cost2010
NOx NAAQS $0.6 B2010 SO2 NAAQS $0.2 B2011 GHG BACT ??2012 Boiler
MACT rules ~$3 B ??2012 Paper Risk and Technology I $5M2012 PM
NAAQS $ 0.1 to >$1 B2013 Paper Off-gas Venting Elimination $1.6
+2014 Pulp Risk and Technology II $3.3 B2014 Pulp and Paper GHG
Rule ??2014 Ozone NAAQS $0.3 to 3 B2015 Wood MACT $0.8 B2016
Cross-state air pollution rule II $0.5 B2016 Hydrogen sulfide MACT
$2.7 B
5. Boiler MACT Starting Point in 2010 Broadest MACT standards
ever under the Clean Air Act Industrial, commercial and
institutional boilers and process heaters at major sources of
hazardous air pollutants. 1,600 facilities and 13,555 boilers
(about 11,000 gas boilers) Emission standards for PM, HCl, Hg, CO,
and dioxin Multiple controls and complex monitoring to meet
limits
6. Initial Boiler MACT Rules June 2010: Responding to court
decision, EPA proposed changes to the Boiler MACT rules. Original
rule would have cost the FP industry $7- $9 billion in capital
costs ($21 billion for all manufacturing). March 2011: EPA issued
original final Boiler MACT -- $7 billion capital cost for FP
industry. Jobs Study by Fisher International: over 20,000 jobs (36
mills) in jeopardy in P&P sector alone. 7
7. Fisher International Study of March 2011 Rules Pulp &
Paper Mill Jobs Mills At Risk 36 20,541 Total 349 113,858 % At Risk
10% 18% 8
8. Re-Proposed Boiler MACT Rules December 2011: The EPA issued
re-proposed Boiler MACT rules. The re-proposed rules would cost the
forest products industry an estimated $4.3 billion. 9
9. Concerted Outreach Effort Allied Industries, Small Business,
Agriculture Labor Congress Bill passed House and almost in Senate
Governors, other state/local officials Administration EPA, USDA,
DOC, SBA/OA, OMB, White House Arguments: economic/employment,
engineering, science, legal, a nd political 10
10. Concerned Trade Groups American Forest & Paper
Association Hardwood Federation American Chemistry Council Hardwood
Plywood & Veneer Association American Coke & Coal Chemicals
Institute Industrial Energy Consumers of America American Foundry
Institute of Shortening and Edible Oils American Home Furnishings
Alliance National Association of Manufacturers American Iron and
Steel Institute National Cotton Ginners Association American
Municipal Power, Inc. National Lime Association American Petroleum
Institute National Mining Association American Public Power
Association National Oil Recyclers Association American Sugar
Alliance National Oilseed Processors Association American Wood
Council National Petrochemical & Refiners Association Alliance
of Automobile Manufacturers National Rural Electric Cooperatives
Association Bioenergy Deployment Consortium Ohio Municipal Electric
Association Biomass Power Association PA Anthracite Council Biomass
Thermal Energy Council Pellet Fuels Association Brick Industries
Association Rubber Manufacturers Association Composite Panel
Association Society of Chemical Manufacturers and Affiliates Corn
Refiners Association Southern Lumber Manufacturing Association
Council of Industrial Boiler Owners The Aluminum Association Edison
Electric Institute Treated Wood Council Fertilizer Institute U.S.
Chamber of Commerce
11. HCl Emissions 2005 US Emissions of HCl by Boiler Type
Utility Boilers: Coal ICI Boilers & Process Heaters - coal ICI
Boilers & Process Heaters ICI Boilers & Process Heaters -
wood or waste Utility Boilers: Oil ICI Boilers & Process
Heaters - natural gas ICI Boilers & Process Heaters - oil
Utility Boilers: Natural Gas Utility Boilers: Wood or Waste
12. Hg Emissions Small Contributors 2005 US Mercury Emissions
By Boiler Type Utility Boilers: Coal ICI Boilers & Process
Heaters - oil ICI Boilers & Process Heaters - coal ICI Boilers
& Process Heaters ICI Boilers & Process Heaters - wood or
waste Utility Boilers: Oil Utility Boilers: Wood or Waste ICI
Boilers & Process Heaters - natural gas
13. SO2 Emissions from Pulp and Paper Mills in PM 2.5
Non-Attainment Areas (15/35, 2010) 4% SO2 Emissions within PM Non-
Attainment Areas SO2 Emissions Outside of PM Non-Attainment Areas
96%
14. Boiler MACT Further Improvements Needed Key Improvements
from 2010 through Dec. 2011 Reproposal: Cost-effective work
practices rather than arbitrary and unachievable limits Emission
limits accounting for variability in performance of top boilers
Adjusted some limits to account for fuel variability Defined more
biomass residuals as fuels Grouping like boilers together separate
biomass from coal Further Improvements Sought: More compliance time
-- one or two years Achievable standards -- esp. carbon monoxide
Classify more biomass residuals as fuels -- encourage renewable,
carbon- neutral alternatives to fossil fuels 16
15. Boiler MACT Estimated CostsEPA Action Cost to Forest Cost
to All EPA Cost Products Sector Manufacturers EstimatesOriginal
Proposal ~$9 B $21 B $11.1 B(June 2010)Original Final $7 B $14.3 B
$6.3 B(March 2011)Reproposal $4.3 B $14.2 B $5.8 B(December
2011)Final ?? ?? ??(2012??)Cost Reductions > $4.7 B >$6.8 B
>$ 5.3 17
16. Paper Risk and Technology Rules Final Clean Air rule
(9/11/12) covers pulping and papermaking operations EPA found
health risks acceptable EPA determined no control technology
upgrades cost effective Costs reduced from $700-900M in proposal to
only $5 M Next Step: litigation by stakeholders More EPA rules
under Paper Sector program Risk & Technology rule Phase II
furnaces and kilns, late 2013 Reevaluate existing venting
allowances summer 2013 Determine if changes to Kraft Pulp New
Source Performance Std court ordered deadline of May 2013 18
17. NAAQS Permitting Gridlock 2010 NOx and SO2 NAAQS plus 2006
particulate matter Modeled emissions exceeding standards stops
projects PM NAAQS June proposal Tighter limits could impose more
than $1 billion in added costs depending on how implemented
Scientific uncertainty questions need for lower limits Ozone NAAQS
proposal in late 2013 Big costs and scientific uncertainty 19
19. Timberland Growth/Removal Ratio By Region 5.00 4.50 Rocky
Mtn 4.00 3.50 3.00 2.50 North 2.00 Pacific Coast 1.50 1.70 1.37
South 1.00 1.22 1.05 0.50 - 1976 1986 1996 2006 North South Rocky
Mtn Pacific Coast 21
20. Biogenic Carbon Emissions Oct. 2009: Fixing A Critical
Accounting Error, Science magazine Dec. 2009: EPA Endangerment
Finding on GHG emissions May 2010: EPA Tailoring Rule to direct
regulations at large emitters July 2011: EPA imposed 3-year
deferral for regulation of biogenic emissions from stationary
sources Sept. 2011: EPA proposed Accounting Framework for Biogenic
CO2 Emissions from Stationary Sources July 2012: EPAs Scientific
Advisory Board (SAB) issued draft report critical of the Agencys
proposed accounting framework; supports anticipated future baseline
22
21. Regulations Can Undermine Competitiveness NERA/MAPI study:
costs of major regulations increased at average rate of 7.6% a year
since 1998. EPA imposes the largest regulatory cost burden on
manufacturing sector ($117 billion in constant 2010 $). Cumulative
impact of major regulations between 1993 and 2011 will lower
manufacturing output by up to 6% over the next decade. Will reduce
paper and wood products output by 6% and 3%, respectively. 23
22. Sustainable Regulations Need for sustainable regulation
(meet economic needs, environmental concerns, and social
expectations) Rigorous application of efficiency criteria and sound
science. Consider employment impacts and need for compliance time;
allow for economic recovery. The incorporation of job losses into
regulatory cost-benefit analyses could alter the calculus for some
propose regulations. 24
23. Wrap-up Uniquely challenging time. Worst economy since the
creation of the modern administrative state. Stubbornly high
unemployment. Aggressive foreign competition. Pressing need for
smarter, more cost-effective regulatory approaches. 25
24. Questions ???Paul NoeVice President for Public
PolicyAmerican Forest & Paper [email protected]
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