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Paper and Wood Products Manufacturing Industries’ ESPS for EGUs Comments Address Potential Business Implications, Role of Biomass in Compliance Strategies

Dec 01, 2014

AF&PA: Jessica McFaul / Chuck Fuqua
(202) 463-2436,
AWC: Heather Stegner 
(202) 463-4756,

WASHINGTON – In joint comments being filed today, the American Forest & Paper Association (AF&PA) and the American Wood Council (AWC) express concern that the U.S. Environmental Protection Agency’s (EPA) proposal on Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Generating Units (EGUs) exceeds the agency’s authority and has potentially harmful implications for business and consumers alike.

“We are concerned that EPA’s proposal will unnecessarily increase energy costs by forcing fuel choices on utilities and impose new requirements on renewable energy providers and users such as paper and wood products manufacturers,” said AF&PA President & CEO Donna Harman. “Under this plan, industrial facilities taking voluntary steps to improve their energy efficiency could be subject to legally enforceable requirements. Moreover, it is clear that EPA has exceeded its legal authority by usurping the role given to states by Section 111(d) of the Clean Air Act to impose performance standards on existing EGUs.”

“If the United States is to remain competitive on a global scale, EPA must recognize biomass-based energy as carbon neutral. The recently released biogenic accounting framework is a step in that direction,” said AWC President and CEO Robert Glowinski. “Other countries around the world use biomass to meet their climate goals. Mandating huge reductions beyond power plants will unnecessarily raise electricity costs for manufacturers, and our industry will incur costs that we simply cannot pass along to consumers, putting us at a competitive disadvantage.”

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Editor’s Note: Complete comments will be submitted to EPA by 5 p.m. today (Dec. 1) and will be forwarded upon request.

About AF&PA
The American Forest & Paper Association (AF&PA) serves to advance a sustainable U.S. pulp, paper, packaging, and wood products manufacturing industry through fact-based public policy and marketplace advocacy.  AF&PA member companies make products essential for everyday life from renewable and recyclable resources and are committed to continuous improvement through the industry’s sustainability initiative - Better Practices, Better Planet 2020.  The forest products industry accounts for approximately 4 percent of the total U.S. manufacturing GDP, manufactures about $210 billion in products annually, and employs nearly 900,000 men and women.  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 or follow us on Twitter @ForestandPaper.

About AWC
The American Wood Council (AWC) is the voice of North American wood products manufacturing, representing over 75 percent of an industry that provides more than 360,000 men and women with family-wage jobs. AWC members make products that are essential to everyday life from a renewable resource that absorbs and sequesters carbon. Staff experts develop state-of-the-art engineering data, technology, and standards for wood products to assure their safe and efficient design, as well as provide information on wood design, green building, and environmental regulations. AWC also advocates for balanced government policies that affect wood products. | @woodcouncil