PPRC Position Paper on Air Permitting

The PPRC recommends that new Clean Air Act rules consider environmental, social, and economic impacts to set sustainable standards and policies to keep our mills competitive and promote job growth in our facilities. Air quality in America has improved dramatically in the last several decades due in part to more efficient, cleaner operating paper mills.

• We support sustainable National Ambient Air Quality Standards (NAAQS). We recommend that EPA withdraw and reconsider the recent PM NAAQS due to its flawed and legally questionable rushed review, the failure to provide a workable implementation plan, and the scientific uncertainties.

• The EPA should exclude paper mills from the final Federal Implementation Plan (FIP) for ozone given the limited impact of our mills and detrimental costs of including them.

• The PPRC feels that excluding minor projects or efficiency initiatives from the permitting process helps to expedite mill improvements that benefit jobs, the environment, and U.S. competitiveness. Many projects, even with state-of-the-art controls, can be cancelled or delayed if unnecessary hurdles are added to the permitting process.

• Many upcoming major regulations, particularly from the EPA, and especially in combination, could have serious unintended consequences for the competitiveness and viability of U.S. paper mills. 

• As the EPA continues to evaluate the effectiveness of Boiler MACT, the PPRC believes the EPA needs to account for the significant progress and investment in reducing emissions and avoid new requirements that are unsustainable for U.S. paper mills.

Implementing air permitting reforms will accelerate job creating projects.