By David M. Wise
WestRock
Pulp and Paperworkers’ Resource Council
National Steering Committee Chairman

I got my start in the forest products industry 26 years ago after serving in the US Army. When I came home (Desert Shield /Storm), there weren’t a lot of good, secure family-wage jobs available in rural South Carolina. You only really had three choices. The railroad, United Parcel Service or the paper mill.

I had always heard that getting a job with the paper mill was like winning the lottery. A job in the forest products industry had everything one could ask for in a job. Secure steady work. A job that had provided an excellent living for generations. Quality low-cost insurance. An abundance of time off and, not to mention, excellent higher-than-average pay.

This was a place I could settle, make a good living, provide for my family and one day retire. You could say I DID win the lottery. My 26-year career at WestRock’s, Florence, South Carolina mill has afforded me the opportunity to send my children to college, buy a nice spacious home and provide my family with new dependable vehicles and much more.

I am not the only lucky one though. The forest products industry has touched more workers than myself. Some mills have as many as three generations working at one facility, and some of our employees are fifth or sixth-generation paper makers. It is a way of life for us, and National Forest Products Week (October 15 -21) is a great time to share it.

Our companies, their employees and families form the heart of our communities. Together, we are a fiercely dedicated group of individuals who stick together as we work to ensure our industry’s future and the health of our environment through sustainable practices. We are American manufacturing, and this is my story.

Throughout my career I have witnessed the ups and downs of our industry. Unfair trade practices, overzealous environmental regulations and legislation that has wreaked havoc on our industry. Smaller mills are closing and continuing acquisitions are creating larger corporations. Many plants have had to endure austerity programs to be able to afford and implement new overly restrictive environmental standards. Some facilities have had to file bankruptcy and close.

When I began my career in the forest products industry in 1996, it employed more than a million people. It now employees around 900,000 men and women. Even with this reduction in jobs, the industry still ranks among the top 10 manufacturers in 45 states and meets a payroll of $50 billion annually. Our industry still accounts for four percent of all U.S. manufacturing GDP.

The people of our industry are dedicated to conservation and sound forest management practices. We realize that without healthy forests and a good clean environment our industry cannot survive, nor can we. That’s why we are dedicated to conserving our environment while we strive to preserve the stability of the work force and contribute to the economy of the surrounding communities.

In rural communities across the U.S., where most of our industry is located, our companies are one of the largest employers in the area. Our payrolls keep the region thriving with employees buying new cars, new houses, new boats and ATV’s. The taxes generated by the mills, the loggers, the supporting companies and their employees play a vital role in the economic stability of the entire community. And, local school districts, city and county offices and agencies, along with local and national merchants depend heavily on the revenue our industry generates.

When someone in town needs surgery, has excessive medical bills or are stricken with a terminal illness, our people are the first to donate, and they donate big and selflessly. Our employees are youth athletic coaches and Boy Scout and Girl Scout leaders. They teach safety in local schools and educate the local school children on the importance of the forest products industry. The list goes on.

There will definitely be more ups and downs, but today and tomorrow, I’ll be on the side of the men and women who are committed to a bright future for the forest products industry. So next time you take a note on a piece of paper at a meeting, wipe a spill up in your kitchen with a paper towel or package up a gift for a relative, take time to remember who we are, what we face as we contribute to the economy and how we are working to make your everyday life just a little bit easier.

ATLANTA – On Wednesday, September 12, 2018 the PPRC, a grassroots organization of hourly employees of the paper and wood products industry, along with Management leaders from several different companies, co‐hosted a joint Labor/Management Conference. The purpose of this conference was to highlight the need to “Grow the Next Generation” of pulp and paper workers in America. It also emphasized the importance of both labor and management working together for a common cause, JOBS!

On that Wednesday morning, after a pledge and a prayer led by PPRC member Robert Gay, approximately 85 hourly and salary individuals watched PPRC Chairman David Wise present AF&PA President and CEO, Donna Harman, the Visionary Award. Chairman Wise said that President Harman is one of the greatest Ambassadors that our industry has to offer. She is a “true pillar” of the PPRC!

Following the agenda for the day everyone was greeted by Michael Amick Jr., Senior Vice‐President, Paper the Americas & India, of International Paper. He discussed Industry and Workforce Development. Mr. Amick said that our industry has a very proud past. He also said, by virtue of everyone being here, he doesn’t think our best days are behind us and he believes we have a bright future ahead of us.

After Mr. Amick spoke, the audience watched the PPRC recruiting video. Several PPRC members made this video and the PPRC uses it when they go recruiting other mills to participate in the PPRC organization. After the video, Mike Mauldin and Bill Kerr of Georgia‐Pacific, and Vinnie Geiser of WestRock all gave a brief talk on why we need new members in the PPRC. The speakers highlighted the need for new members and their ability to communicate with other people their age through social media avenues. There is also a need for younger people to get interested in skilled trades.

The next speaker was Donna Harman, President and CEO of the American Forest and Paper Association (AF&PA). Mrs. Harman thanked the PPRC for her Visionary Award. She went on to talk about how we must all now engage with the “New Generation” on Capitol Hill.

After Mrs. Harman, the CEO of the WestRock Company, Steve Voorhees, discussed “Growing the Next Generation”. Mr. Voorhees started by saying “Thank You” to all PPRC members. He talked about how we all came together when we hosted the Congressional Reception in the Capitol this past year. He commented on the impression it made on him knowing that WestRock had 27 PPRC representatives from 11 locations represented at the DC Fly‐In. Mr. Voorhees told us that WestRock is making appearances in Trade and High Schools and partnering with local colleges to help keep our industry alive.

The next speaker was Tim O’Hara, Manager & Policy Communications Director for the Forest Resource Association. Mr. O’Hara talked about our Industry’s Transportation Challenges. The challenges range from lack of drivers due to retirement and the future growth of this industry. There are also several factors such as insurance and regulations costs that seem to be hurting the transportation industry.

After Mr. O’Hara spoke, John Rooney, CEO of Graham‐Evergreen‐Closure System or GEC Packaging Technologies talked about “Helping a New Generation Understand Our Industry”. Mr. Rooney thanked the group for inviting him back and for our work that we do at the DC Fly‐In. Mr. Rooney said the top 3 issues for our industry is demand for our products, regulatory compliance, and making sure we are bringing new folks into our industry.

After Mr. Rooney spoke, Bill Moyers of Georgia‐Pacific, led the group in prayer for a lunch that was provided by Georgia‐Pacific.

After lunch, Russ Wanke, President and CEO of Expera Specialty Solutions, talked about “Why the Work of the PPRC is so Important”.

Mr. Wanke said that a lot of the work the PPRC does is around regulatory compliance. He said he is proud that our group is working with legislatures to “seek a balance” in their rule making. He went on to describe how the costs of regulatory compliance can directly affect not only the company and its’ workers but also the communities around them.

The next speaker was Christian Fischer, President and CEO of Georgia‐Pacific. Mr. Fischer emphasized “Innovations”. Mr. Fischer talked about how our industry has taken advantage of technology. Our industry has become very automated. He said young people should be attracted to our industry if we show how advanced we have become. Mr. Fischer said that technology can make us safer and more productive.

After Mr. Fischer, the next speaker was Donnie Colston, Director of the Utility Department at the International Brotherhood of Electrical Workers Union. Mr. Colston told us that the IBEW also has a large roll in the regulatory process. He said that the IBEW is proud to work with this industry on regulatory issues. Mr. Colston said that just 15 years ago the IBEW represented over 350,000 members in its manufacturing department. Today it is less than 100,000 members. Mr. Colston also talked about getting IBEW members trained in the “Code of Excellence” program which trains workers to have a sense of pride in their work. He also talked about the IBEW “Renew” Program, which stands for, Reach out and Engage the Next generation of Electrical Workers. It focuses on how we get the next generation engaged, how we teach them, and how we get them to understand what professionalism is.

The next speaker was Mark Rey, the Executive Director of the Forest Products Industry National‐Labor Management Committee. Mr. Rey discussed the importance of L&M working together to preserve our industry. Mr. Rey commented that the PPRC is approaching its 30‐year anniversary date. The PPRC started in 1989 when the Carpenter’s Union Officers came to the Forest Products Industry about the spotted owl issue and the way it was affecting jobs in the Pacific Northwest. Two years later, the PPRC was formed. He said he believes this group is the longest running labor/management organization working at the National level under the Taft‐Hartley Act. Mr. Rey said that now, we as an industry face air, water, and other environmental regulations. Mr. Rey also gave us information concerning the upcoming elections.

Chairman David Wise thanked all the speakers who took their time to discuss ways to grow the next generation. He also thanked the children of PPRC member, John Peacock, who took their own money and purchased the pens and divot tools that were given away as keepsakes. He also thanked WestRock who donated the cups and portfolios. Chairman Wise also thanked Georgia‐Pacific for sponsoring the lunch today and International Paper Company for sponsoring the meet and greet reception held last night. He then asked PPRC member Gerry Mims to close our conference in prayer.

Meeting adjourned.

By Donna Harman
President & CEO
American Forest & Paper Association

We take advantage of every opportunity to advance realistic public policy that supports the pulp, paper, packaging, tissue and wood products industry and its hardworking employees. Right now, opportunities are abundant for common sense federal regulatory reforms in Congress and the administration.

Already this year, AF&PA has sprung into action seeking reforms that will help our economy grow and continue to create American manufacturing jobs. We look forward to building on the message we recently delivered to Capitol Hill.

When it comes to federal air permitting compliance, our businesses face a challenging area of regulation. Members of Congress at their House Energy and Commerce Environment Subcommittee hearing entitled, “New Source Review (NSR) Permitting Challenges for Manufacturing and Infrastructure” listened to our request for serious reform to the NSR program.

At the same time, members of the Pulp and Paperworkers’ Resource Council – the men and women who work tirelessly on company front lines – echoed the need for regulatory reform across Washington during their annual fly-in. More than 70 PPRC members logged 485 Congressional and administration office visits to educate decision makers about a range of issues, and we couldn’t be more grateful for that backup and steady commitment.

The NSR program requires multiple layers of analysis and inappropriately captures many smaller projects that would benefit the environment by allowing upgrades of existing equipment to be more energy efficient. At the NSR hearing, Paul Noe, AF&PA Vice President of Public Policy, testified that the EPA needs to modernize a broken NSR permitting system in order achieve the twin purposes of the Clean Air Act to promote public health and welfare as well as the productive capacity of the nation.

Here’s the state of play. Our industry has invested billions of dollars on environmental stewardship and remains committed to innovative and sustainable business practices. Yet, an inflexible and overly complicated NSR permitting program is impeding beneficial projects and job creation and undermining paper and wood product manufacturers’ ability to effectively plan for their future. Here’s the solution. The time is now for the EPA to adopt flexible policies and realistic emissions data and modeling that will support our industry.

Before taking questions from members of Congress, Noe stated, “Our shared goal should be sustainable regulation – regulation that addresses environmental and economic needs. I believe there is no better place for a robust manufacturing sector than the United States, which has highly-productive workers, creative entrepreneurs and innovators, abundant resources, a strong free-market democracy and regulatory agencies capable of leading the world on sustainable regulation.” 

We are grateful to have had the opportunity to make the case for NSR reform to Congress and are focused on delivering solutions here and across all our 2018 advocacy priorities. On that path, we’ll continue to work with and support stakeholders like the PPRC whose scheduling director Glenda Thompson summarized the impact of ill-advised policies in a recent AF&PA guest blog:

“PPRC members know that many times our representatives in Washington don’t know the full ramifications of their decisions. We understand how overzealous regulation and legislation can destroy businesses, communities, and lives. We all believe that environmental regulations are necessary. We live and recreate in the areas around our mills. We want clean air and water. We also want common sense regulation, not knee-jerk reactions that are overreaching and burdensome to the point that it is no longer economically feasible for a company to continue to do business.”

Fortunately, NSR and permit reform is also a big priority for the administration. EPA Assistant Administrator for Air, Bill Wehrum, has identified NSR permitting reforms as one of his top priorities for the year.

Stay tuned for results of our work with Congress, the administration, key decision makers and stakeholders to deliver results that ensure our industry has every opportunity to strengthen its roots and grow for generations to come.

Lieutenant General Todd T. Semonite
Commanding General and Chief of Engineers
U.S, Army Corps of Engineers
441 G St NW
Washington, DC 20314

Dear Lieutenant General Semonite:

The undersigned organizations understand and appreciate your commitment to the cooperative federalism principles embedded in the Clean Water Act (CWA). As explained herein, however, we are concerned that the recent actions of the Jacksonville District of the U.S. Army Corps of Engineers (Corps) run counter to those cooperative federalism principles as well as the plain text of CWA Section 404(g). These actions will serve to delay and frustrate Florida’s assumption of the Section 404 permitting program. We ask that you intercede. Specifically, we ask that the Corps Jacksonville District Office: (1) withdraw its March 19th initiative, (2) withdraw its dubious addition of numerous, non-assumable Florida waters in October 2017, and (3) delineate Florida’s assumable waters consistent with the Assumable Waters Subcommittee’s majority recommendations.

The March 19th District initiative is unnecessary. The Jacksonville District’s stated purpose of the request for comments is to assist the District with determining the extent of waters over which to retain permitting authority if EPA approves Florida’s Section 404 program application. The notice cites no legal authority compelling this outreach initiative. Seemingly, there is none. The District notice also cites no evidence that Florida is beset with previously overlooked non-assumable waters. We are unaware of any such factual basis. Indeed, this new initiative comes on the heels of the District’s unexplained expanded list of “navigable waters” in October 2017, which tripled the number of streams and added more than 1,000 lakes, including questionable additions, not only because they are not used in transport of interstate commerce, but additions so small one would strain to find them on a map.

Notably, the District’s recent efforts coincide with the State of Florida’s effort to assume Section 404 permitting authority.

The Jacksonville District should be singularly focused on identifying Florida Rivers & Harbors Act Section 10 waters consistent with CWA Section 404(g)(1) and the Final Report of the Assumable Waters Subcommittee. The undersigned respectfully ask that the District comply with CWA Section 404(g)(1), follow the majority recommendations of the national Final Report of the Assumable Waters Subcommittee (Report), and work with the State of Florida to determine the extent of Florida’s permitting authority. The Report provides guideposts for determining the extent of waters that are to be assumed by a state (assumable waters) and retained by the Corps (non-assumable waters) pursuant to CWA Section 404(g). The Report is supported by all the Subcommittee’s members representing environmental organizations, the private sector, and state and tribal officials. The only dissenting opinion came from the Corps itself.

The Corps’ minority recommendations are inconsistent with the plain language of the Clean Water Act, the legislative history, and underlying rules. The law is clear on identifying which waters must be retained by the Corps: waters that are presently used or are susceptible to use to transport interstate or foreign commerce – i.e., Rivers & Harbors Act waters, except waters that are subject to Rivers & Harbors Act solely because they were used in the past to transport interstate commerce. The Subcommittee’s recommendation reflects this clear distinction.

The District’s March 19th notice, however, ignores the CWA’s text and its legislative history. The notice instead reflects the Corps’ minority opinion in the Report and signals an attempt to expand the scope of the Corps’ retained waters, which would be contrary to law. We ask that the Corps abandon the District’s March 19th initiative and instead determine non-assumable waters in a manner consistent with the Report and the CWA.

The District initiative subverts the Clean Water Act’s cooperative federalism structure. The CWA is a balanced, cooperative federalism statute. It is troubling to see that the March 19th notice tips that balance, as it specifically references rivers, streams, and lakes associated with past commerce or recreational activities as potentially retained waters. As noted above, the District should not consider past commercial uses of waters.

Additionally, nothing in Section 404(g) or the implementing regulations makes any reference to waters used for recreational purposes. Section 404(g) is clear that the Corps is only authorized to retain those waters used or may be used “to transport interstate or foreign commerce.” Moreover, the Corps’ own regulations demonstrate that the District should not seek to retain permitting authority over certain waters based solely on the fact that the water supports or may conceivably support recreational activities. 33 C.F.R. § 329.6(a).

To expand Corps’ authority is to upset the cooperative federalism balance of the CWA. The CWA cast the states as the lead players; the federal government assumes an oversight role. Consistent with that structure, forty-six states now implement the authority granted by Section 402 of the CWA through administration of the National Pollutant Discharge Elimination System (NPDES) permitting program applicable to discharges of pollutants. Only two states, however, have assumed Section 404 permitting authority. The disparity is telling.

It need not be this way. We ask that the District help reinvigorate the cooperative federalism spirit of the Section 404 program. The District should implement Section 404(g) as Congress intended and adopt the majority recommendations of the Assumable Waters Subcommittee when determining which waters must be retained. We respectfully ask that the Corps abandon the Jacksonville District March 19th initiative and withdraw its dubious addition of numerous, non-assumable Florida waters in October 2017.

Sincerely,

American Council of Engineering Companies of Florida
Associated Industries of Florida
Association of Florida Community Developers
Florida Cattlemen Association
Florida Chamber of Commerce
Florida Electric Power Coordinating Group, Environmental Committee
Florida Engineering Society
Florida Farm Bureau Federation
Florida Fertilizer and Agrichemical Association
Florida Forestry Association
Florida Fruit and Vegetable Association
Florida H2O Coalition
Florida Home Builders Association
Florida Nursery, Growers and Landscape Association
Florida Ports Council
Greater Orlando Builders Association
Home Builders Association of West Florida
Lee Building Industry Association
Manufactures Association of Florida
Polk County Builders Association
Pulp and Paper Resource Council
Rayonier
Southeast Milk, Inc.
Tampa Bay Builders Association
Treasure Coast Builders Association
Volusia Building Industry Association

By Robert E. Gay Sr.

Virginia is a leader in developing an innovative and diverse energy marketplace to ensure the state’s economy will remain competitive well into the future. However, a new regulation being developed by the Department of Environmental Quality could create an unprecedented threat to one of the pillars of Virginia’s energy future.

Forest biomass powers Virginia’s economy. More than 27,000 Virginians make a living in the commonwealth’s forestry and forest products industry, which includes manufacturers of pulp, paper, packaging, tissue, and wood products. They make nearly $7.4 billion in products, earn a total payroll of almost $1.5 billion a year, and generate annual state and local tax revenue of $155 million. Forest biomass also powers many of the facilities in which this economic activity takes place.

Paper and wood products mills in Virginia and around the country use forest biomass residuals from their manufacturing processes to power their operations, reducing their need to purchase electricity from the grid and making use of material that could otherwise be sent to landfill. Power generated throughout that process does not contribute to the buildup of greenhouse gases in the atmosphere. According to research in the Journal of Industrial Ecology, using residuals this way produces a greenhouse gas reduction benefit over a single year equal to removing 1 million cars from the road.

Consistent with the United Nations’ Kyoto Protocol and the policies of other nations around the world, biomass energy should be considered carbon neutral [in Virginia]. Data from the U.S. Forest Service indicate that timberlands in Virginia grew more than twice as much wood as was harvested in 2016 — wood that is sequestering carbon — while the U.S. as a whole also grew nearly twice as much wood as was harvested. These sustainable manufacturing practices should be rewarded, not penalized. Virginia’s manufacturing facilities are competing with companies in Europe and elsewhere, and the biomass energy of those competitors is recognized as carbon neutral and, in some cases, handsomely rewarded.

Virginia’s DEQ seems to be moving in the opposite direction. A draft regulation from the DEQ’s Air Pollution Control Board would, for the first time in any state, classify an electric generating facility as fossil fuel-fired and subject to additional regulations if just over 10 percent of the fuel mix it uses is fossil fuel and the remainder is forest biomass.

This approach is not supported by science, is inconsistent with the model rule of the Regional Greenhouse Gas Initiative (RGGI), which is what prompted this regulation in the first place, and would set a dangerous precedent for other states considering how best to support carbon-neutral energy.

Forest biomass residuals sometimes are mixed with small amounts of fossil fuels, but research shows that mix does not change the carbon profile of the biomass. The physical and life cycle characteristics of the biomass remain the same regardless of whether or not it is co-fired with a fossil fuel — thus, the 10 percent threshold is entirely arbitrary.

DEQ can and should do better by using a science-based approach that acknowledges the real-world attributes of forest biomass and its contribution to carbon-neutral power generation. The proposed regulation should be updated to reflect the reality that the carbon profile of biomass has no credible connection to the amount of fossil fuels that may or may not be fired in the same generator. The proposed regulation can be improved further by removing language stipulating that Virginia join RGGI — a legislative question, not a regulatory one. Also, the proposed regulation should indicate clearly that the DEQ maintains the current exemption for industrial boilers.

The forest products industry is a top 10 manufacturing sector employer in 45 states, meaning thousands of facilities across the country are generating carbon-neutral power by using forest biomass residuals. As a recognized leader on energy policy, Virginia can use this regulatory process to set a clear, science-based standard other states can follow: Forest biomass is an important carbon-neutral and renewable source of power that supports a vibrant manufacturing sector.

Robert E. Gay Sr. is a general mechanic at WestRock, and a senior mill representative to the Pulp & Paperworkers’ Resource Council, both in Hopewell. Contact him at robert.gay@westrock.com.

David K. Paylor, Director, Virginia Environmental Quality
Michael G. Dowd, Director, Air and Renewable Energy Division
Virginia Department of Environmental Quality
629 E. Main Street
Richmond, VA 23219

Dear Director, Paylor and Director Dowd:

On behalf of the Pulp & Paperworkers’ Resource Council (PPRC), I appreciate the opportunity to comment on the Commonwealth of Virginia’s proposed “Regulation for Emissions Trading” for the CO2 Budget Trading Program.

The PPRC is a non-profit grassroots organization made up of ground floor hourly workers in the forest products industries. We come from across the United States. The PPRC is committed to educating our policy makers on issues of importance to the forest products industry and the impact policies have on our jobs and communities.

In Virginia, the forest products industry operates 46 manufacturing facilities and employs more than 27,000 individuals with an annual payroll of over $1.1 billion and produces $7.3 billion in product each year. The estimated state and local taxes paid by the Virginia forest products industry totals $155 million annually.

PPRC does not support Virginia joining RGGI because it will raise electric power prices and consequently cause Virginia-based businesses to become less competitive. However, if the state does join RGGI, we urge that DEQ maintain the exemption for industrial boilers and ensure that biogenic carbon dioxide emissions are considered carbon neutral.

Biogenic carbon dioxide emissions from forest-derived bioenergy categorically should be counted as making zero contribution to the build-up of greenhouse gases in the atmosphere where timberland carbon stocks are stable or increasing. Through the natural carbon cycle, growing forests sequester carbon as trees continually are replanted and grow through their lifecycles, even as some trees are being harvested.

The most recent data from the U.S. Forest Service indicate that timberlands in Virginia, the U.S. South, and the entire U.S. have highly positive net growth vs. removal ratios.

We appreciate your consideration of these comments and look forward to continuing our work with the Commonwealth of Virginia on this very important issue. If you have any questions, please do not hesitate to contact me.

Sincerely,

David M. Wise
Pulp and Paperworkers’ Resource Council
National Steering Committee Chairman
Southeast Region Director
POB 100544
Florence, SC 29502-544
david.wise@westrock.com
(843) 269-0164

WASHINGTON, Feb. 13, 2015 /PRNewswire/ — American workers employed in the U.S. forest products industry visited Washington, D.C. this week to meet with members of Congress and administration officials. Their goal was to educate elected and appointed officials and staffers on the impact of legislative and regulatory decisions both on the environment and on the families and communities that depend on forest products manufacturing for their livelihood.

The Pulp & Paperworkers’ Resource Council (PPRC) is a grassroots organization of hourly employees of the forest products industry who educate on issues that impact jobs in their industry. More than 70 PPRC members from across the U.S. were in Washington this week to discuss several issues including the carbon neutrality of biomass and manufacturing byproducts, clean water, the regulatory burden impacting American manufacturing, endangered species, renewable energy, greenhouse gas regulations, truck weight reform and ensuring the competitiveness of the U.S. forest products industry.

In addition to meeting with their members of Congress, PPRC members met with administration officials of the OMB, EPA, CEQ, Senate Minority Whip Durbin, House Majority Leader Cornyn, Honorable Steny Hoyer-Democratic Whip, Speaker of the House Boehner, DOT, Office of the Vice President, Senate President Pro Tem Orrin Hatch, Joint meeting with the Department of Interior & U.S. Fish & Wild Life, and the Forest Service. During their three days of meetings, PPRC members made 404 legislative and administration visits.

“We are at a time in this country where there is a glimmer of economic recovery, but communities around the country still need the types of good-paying jobs that forest products manufacturing provides – whether it’s making paper, building products, bath tissue or boxes,” said Patti Barber, PPRC chairwoman. “We make products that Americans use every day. The PPRC believes that our elected and government officials need to protect the environment while at the same time support the health and competitiveness of the U.S.

Forest Products Industry. Burdensome regulations and legislation ultimately only hurt the U.S. workers we represent and the communities where we live, work and play. Our industry represents more than 4 percent of the total U.S. manufacturing GDP; it employs about 900,000 people – many in small, rural communities; generates total wages of approximately $50 billion in communities across our country; and is among the top 10 manufacturing sector employers in 47 states.”

Issues that PPRC members addressed included:

• Carbon Neutrality of Biomass and Greenhouse Gas Regulations: The biomass harvested from sustainably managed forests has been recognized repeatedly as being carbon neutral by an abundance of studies, agencies, institutions, legislation and rules around the world. But EPA’s proposed greenhouse gas (GHG) regulation of existing utilities is immensely expensive and raises many concerns regarding when biomass will be carbon neutral. Paper and wood manufacturers have always sought to use the “whole tree”, including using biomass residues from sustainable forestry operations to produce energy, displacing fossil fuel use and providing significant carbon reduction benefits to the environment.
• Clean Water: The Clean Water Act and its implementing regulations are one of our nation’s most successful and wide-ranging environmental programs. A proposed rule change by the EPA and the Corp. of Engineers would radically impact the original intent of the Clean Water Act, essentially giving those two organizations the right to regulate all waters of the U.S., expanding authority beyond “navigable” waters and even include agricultural field ditches and other water bodies and ditches that have been man-made. Should the proposed rule move forward unchanged, the economic impacts across nearly every sector of the economy and the strain on our states would be substantial.
• Cumulative Regulatory Burden: EPA should examine the sustainability of its regulatory program to embrace a balanced approach so costly air and other regulations will protect the public’s health while preserving family-wage manufacturing jobs. New ozone regulations could cost billions of dollars per year and place thousands of jobs at risk and could be the costliest regulation in history. In states and areas in which the EPA will classify as being in “nonattainment” with the Ozone Standard, manufacturers in those states will not be able to expand their business without other businesses in the area reducing emissions or shutting down. Economic expansion in these areas will slow dramatically.
• Endangered Species Act: The U.S. Fish and Wildlife Service is considering listing the northern long eared bat as endangered. These bats roam in 39 states and are dying in some of those states due to a fungus called “white noise syndrome.” The presence and spread of this fungus is not related to forest management activities. In well-managed forests where the fungus has not been found, the bats are thriving. Listing this bat as endangered will create serious concern regarding fiber supply for the forest products industry, which includes restrictions on harvesting fiber from April to October. Efforts should focus on curing the fungus rather than attempting to regulate forest habitat.
• Truck Weights: The PPRC supports legislation to allow states to increase the weight limit on trucks traveling on interstate highways. More than 40 states already allow
• heavier trucks on state roads.

“The PPRC believes it is vital to help elected and appointed officials understand how critical the forest products industry is to the health of the U.S. economy and the environment. We believe in balancing our environmental needs while securing existing manufacturing-based jobs in our local communities,” Barber said.

The United States is one of the world’s most diverse exporters of sustainable forest products. Exports account for about 15 percent of total U.S. forest products sales. The industry also generates economic benefits from indirect exports – such as domestic sales of paper, paperboard and wood packaging materials – that are used to package and transport goods exported by other U.S. industries.

WASHINGTON – Nearly 70 members of the Pulp and Paperworkers’ Resource Council (PPRC) will take their issues and concerns regarding the paper and wood products manufacturing industry directly to members of the U.S. House, Senate and administration during the organization’s annual Washington, DC Fly-in from Feb. 12 – 15.

The PPRC is a 27-year-old grassroots organization of hourly employees of the paper and wood products industry who voluntarily serve to educate on issues that impact jobs and economic growth in their industry. The Council has scheduled almost 275 meetings with offices on Capitol Hill and across Washington for meetings during the fly-in. Their goal is to educate officials on the impact of legislative and regulatory decisions on the families and communities that depend on forest products manufacturing for their livelihood.

“Communities around the country need the types of good-paying jobs that forest products manufacturing provides – whether it’s making paper, building products, bath tissue or boxes – products Americans use every day,” said David Wise, PPRC chairman. “The PPRC believes that our elected and government officials need to protect the environment while at the same time support the global competitiveness of the U.S. paper and wood products industry. Overly burdensome regulations and legislation ultimately hurt the U.S. workers we represent and the communities where we live, work and play.”

The forest products industry represents more than four percent of the total U.S. manufacturing GDP and employs about 900,000 people – many in small, rural communities. The industry generates total wages of approximately $50 billion and is among the top 10 manufacturing sector employers in 45 states.

Media Contact: David Wise, PPRC Chairman; (843) 269-0164, (843) 319-7189

CRC proposal 23, if adopted, would essentially take Florida back to a period of time prior to the passage of the Florida APA and environmental legislation. This amendment would allow case by case implementation of the Florida environmental regulation, rather than the comprehensive regulatory system in place today. Environmental policy would effectively be made piecemeal by the courts rather than by historical agencies and the Legislature. There is already provision for the protection of natural resources and scenic beauty with-in the current Constitution in Article II, Section 7[a].

Therefore, the Pulp and Paperworkers Resource Council [PPRC] is in opposition of CRC Proposal 23. Your consideration of this letter will be greatly appreciated.

Sincerely,

J. Michael Mauldin
PPRC National Special Projects Coordinator

Dear Ms. Downing:

The Pulp & Paperworkers’ Resource Council (PPRC) appreciates the opportunity to comment on the U.S. Environmental Protection Agency’s (EPA) and the U.S. Army Corps of Engineers’ (Corps) (together, “the Agencies”) proposed rule: Definition of “Waters of the United States”—Recodification of Pre-existing Rules. 82 Fed. Reg. 34899 (July 27, 2017) (“Proposed Rule”).

The PPRC is a grassroots organization representing the interests of the nation’s pulp, paper, solid wood products, and other natural resource-based workers. The U.S. forest products industry is vitally important to our nation’s economy, employing 900,000 people. We rank among the top 10 manufacturers in 45 states and represent 4% of the total Gross Domestic Products (GDP). We are people dedicated to conserving the environment while taking into account the economic stability of the workforce and surrounding community.

PPRC members are employed by companies with membership in the American Forest & Paper Association (AF&PA) and supports and incorporates by reference the comments filed by AF&PA. PPRC supports the Agencies’ proposal to rescind the Clean Water Act (CWA) Rule: Definition of “Waters of the United States (WOTUS) (the 2015 Rule)” and recodify the status quo that is now being implemented under the Sixth Circuit stay of the 2015 Rule. The Agencies should rescind the 2015 Rule because its provisions are, in various respects, beyond the Agencies’ statutory authority, inconsistent with Supreme Court precedent, and contrary to the goals of the CWA, including the Act’s goal to “recognize, preserve, and protect the primary responsibilities and rights of States to prevent, reduce, and eliminate pollution.” 33 U.S.C. § 1251(b). The Agencies failure to seek meaningful input from state and local entities during the development of the 2015 Rule contributed to the rule’s legal flaws and lack of clarity.

Of particular importance to PPRC, whose companies are subject to regulation under the CWA, is the regulatory uncertainty that flows from the 2015 Rule’s lack of clarity on key terms and definitions, such as “tributary,” “adjacent,” “floodplain,” and “significant nexus.” In particular, We work at pulp and paper mills that must obtain CWA permits to operate their facilities. Most of those mills operate near waters that would be considered jurisdictional waters. Due to these expansive definitions, the jurisdictional status of waters on their facilities is called into question.

The 2015 Rule improperly reads the word “navigable” out of the statute, and implicates significant constitutional concerns about the appropriate scope of federal authority. Furthermore, nothing in the record created during the 2015 rulemaking process dictated the adoption of such a sweeping definition of “waters of the United States.” The agencies properly acknowledged in the record for the 2015 rule that their interpretation of the CWA is “informed” by the scientific record and the comments of the Science Advisory Board, “but not dictated by them.” Technical Support Document for the Clean Water Rule at 93. Nonetheless, the agencies adopted a fatally flawed interpretation of the statute that intrudes upon state and local authority over land and water use in direct defiance of Congress’s stated policy in Section 101(b).

To address these concerns, the Agencies should rescind the 2015 Rule and recodify the regulations in place immediately prior so that the Code of Federal Regulations accurately reflects the regulations as they existed prior to the 2015 Rule’s amendments. Since the Sixth Circuit’s October 2015 issuance of a nationwide stay, the Agencies have been implementing the regulations defining WOTUS that were in effect before the 2015 Rule. The proposed action would simply continue that practice and recodify the status quo that has been in place for decades.

Finally, PPRC supports the Agencies’ efforts to undertake a substantiverulemaking to reconsider the definition of “waters of the United States.” Although codifying the status quo is important to ensure clarity and regulatory certainty in the near term, there are many issues with the current regulations and guidance documents that should be addressed through a new rulemaking. PPRC will continue to support a rulemaking to clearly articulate the extent of federal CWA authority.

Thank you for the opportunity to comment on the Proposed Rule.

Sincerely,
David M. Wise
Pulp and Paperworkers’ Resource Council
National Steering Committee Chairman
Southeast Region Director
POB 100544
Florence, SC 29502-544
david.wise@westrock.com
(843)269-0164
(843)319-7189m