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

Dear David:

On behalf of AF&PA members and our team, I want to thank you, the Pulp & Paperworkers’ Resource Council Steering Committee, and all PPRC members for your work in support of the carbon neutrality legislative language that was included in the final FY 2017 appropriations bill. This is an important accomplishment for paper manufacturers and our workforce.

The outreach of the PPRC to Congress and the Administration over the course of the several few years, and most recently during the 2017 Fly-In, made a difference. The op-eds placed in certain states by Steering Committee members last October was also extremely helpful in raising the political visibility of the issue during the campaign season.

We are beginning our strategy and advocacy plans to have the legislation implemented by the EPA, USDA, and DOE. We look forward to our continued partnership on this and other issues that benefit our industry.

Thank you again for making a difference!

Best Regards,

Donna A. Harman
President and Chief Executive Officer

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 officials on the impacts of legislative and regulatory decisions on the environment as well as 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 in the forest products industry who educate on issues that affect American manufacturing jobs in their industry. During their three days of meetings, 73 PPRC members made 544 legislative and administration visits, including the office of the Vice President.

“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. forest products industry. Overly burdensome regulations and legislation ultimately hurt the U.S. workers we represent, our families, friends and neighbors that live in our communities.”

PPRC members from across the U.S. discussed several issues, including:

• Regulatory reform. The regulatory system is a drag on our economy, job creation and the ability of the U.S. industry to compete globally. The PPRC seeks a more balanced and economical approach that does more good than harm, is based on sound science, and is transparent and accountable to the public.
• The carbon neutrality of biomass and manufacturing byproducts. The carbon neutrality of biomass harvested from sustainably managed forests has been recognized repeatedly by agencies and institutions around the world. Forest products industry manufacturers use biomass residuals to power their facilities, reducing fossil fuel use and providing significant carbon reduction benefits to the environment. The PPRC urges policymakers to formally recognize the industry’s use of biomass for energy as carbon neutral.
• Endangered species. Forest products industry employees support Endangered Species Act (ESA) reform. The ESA needs to be modernized and updated after 30 years.
• Fish consumption (human health water quality criteria [HHWQC]). At a national and state level, the EPA has been imposing policies based on unrealistic assumptions that will make HHWQC more stringent, resulting in more waters being listed as impaired and creating extremely costly, unattainable permit limits for manufacturers.
• Preserving paper options for consumers. The PPRC supports policies that recognize paper-based communications are critically important for millions of Americans. The move to digitize all forms of communication creates a disadvantage for American households without internet access and the 45 percent of seniors who do not own a computer. Increasingly, citizens are being denied the option to receive federal services and communications in paper format.

In addition, PPRC members thanked senators and members of Congress who have joined the Paper and Packaging Caucus, while requesting others join the Caucus.

The U.S. forest products industry is vitally important to our nation’s economy, employing about 900,000 people – many in small, rural communities. It ranks among the top 10 manufacturers in 45 states and represents four percent of U.S. manufacturing GDP. The PPRC is dedicated to conserving the environment while taking into account the economic stability of American manufacturing workers and their mills’ surrounding communities.

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

Concerned about global temperatures, Washington is phasing out electricity generated from coal – once the mainstay of, among many other applications, US Navy ship propulsion. Renewables such as wind, solar and, for Virginia especially, forest biomass (wood and byproducts derived from sustainable forest management and from paper and wood products manufacturing facilities) are favored alternatives. But now a policy impasse in Washington risks making forest-sourced biomass an energy outcast, too. Only Congress can break the bureaucratic gridlock.

At issue is a rulemaking in 2010 that suddenly and without public notice or proper scientific review reversed federal policy and regulated forest biomass the same as fossil fuels. Because of this radical departure and demands to modify the rule, the government put the rule on hold to study the science. Today—six years later and without a clear path forward—uncertainty remains for energy producers, forest owners and manufacturers that rely on forest biomass for energy. Building new facilities, retrofitting existing ones, and installing necessary emission control technologies dedicated to the fuel requires significant planning and investment. Washington’s policy paralysis has thrown an economic and environmental disincentive in the way of that essential investment.

The problem, the regulators say, is measuring the carbon impacts from forest biomass. However, the carbon benefits of woody biomass are well established, as 100 leading forestry scientists from around the U.S. have repeatedly stated in letters to the government. Those scientists cite the most comprehensive survey of peer-reviewed literature in their field concluding that, “[D]emand for wood helps keep land in forest and incentivizes investments in new and more productive forests, all of which have significant carbon benefits.”

In the U.S, the strong markets for wood products including biomass are why the volume of trees in our forests has increase 50% since the 1950s. In Virginia, despite massive post-World War II suburbanization, our state has nearly a million more acres in forestland than it did in 1940 and forest-dependent industries like logging, wood products, and pulp & paper employ over 27,000 workers. Today, our total U.S. forests offset 13 percent of total CO2 emissions annually. Those offsets are precisely why the Fourth Assessment Report of the Intergovernmental Panel on Climate Change stated, “In the long term, a sustainable forest management strategy aimed at maintaining or increasing forest carbon stocks, while producing an annual sustained yield of timber, fiber or energy from the forest, will generate the largest sustained [carbon] mitigation benefit.”

Washington’s indecision also may put U.S. policy at odds with the Paris Agreement on climate change, adopted last December. That global agreement underlines the importance of “positive incentives for … sustainable management of forests and enhancement of forest carbon stock.” It urges signers to “take action to implement and support” expansion of the global volume of trees.

Congress is working on solutions, but can it act before it adjourns? A Senate-passed energy bill provides a policy establishing the carbon benefits of forest biomass, and the Senate Interior Appropriations bill includes specific guidance on how to get that done. One way or the other, it is essential for Congress to put the US back in line with the global norm and affirm the carbon benefits of forest biomass.

Tens of thousands of Virginia jobs with manufacturing-level wages and the quality of our global environment are at stake. The international community continues to recognize that forest biomass energy is essential to a scientifically sustainable climate policy. It is time the United States did the same — again.