\"Schwartz, Jerry\" \<Jerry_Schwartz@afandpa.org\>

10/10/2006 05:50 PM

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Group Ow-Docket@EPA

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Subject

AF&PA Comments for Docket No. EPA-HQ-OW-2006-0656

Please include the attached AF&PA comments on the EPA Mercury

Implementation Guidance document in docket No. EPA-HQ-OW-2006-0656. If

you have any questions, my contact information is below. Thank you.

Jerry Schwartz

Senior Director

American Forest & Paper Association

1111 19th Street, N.W.

Suite 800

Washington, D.C. 20036

Phone: (202) 463-2581

Fax: (202) 463-2423

jerry_schwartz@afandpa.org

# ![](media/image1.jpeg){width="0.5868055555555556in" height="0.9736111111111111in"} 

> October 10, 2006

(Via Email)

Water Docket

Environmental Protection Agency (4101T)

U.S. EPA

1200 Pennsylvania Ave., N.W.

Washington, D.C. 20460

> Re: AF&PA Comments on Draft Guidance for Implementing the January 2001
> Methylmercury Water Quality Criterion ("Guidance"), [Docket ID No.
> EPA--HQ--OW--2006--0656]{.underline}, 71 *Fed. Reg.* 45560 (August 9,
> 2006)

To Whom It May Concern:

The American Forest & Paper Association (AF&PA) is pleased to submit
these comments on the draft Guidance. AF&PA is the national trade
association of the forest, paper and wood products industry. Our
organization represents approximately 250 member companies and related
trade associations that grow, harvest, and process wood and wood fiber;
manufacture pulp, paper and paperboard from both virgin and recycled
fiber; and produce solid wood products. AF&PA members own and operate
facilities that may be covered by permits issued pursuant to the
Guidance. Therefore, AF&PA has a direct interest in the Guidance. We are
also a signatory to the comments which will be provided by the Federal
Water Quality Coalition (FWQC), and we support them in their entirety.
Our comments below are limited to one issue raised in the Guidance.

The Guidance discusses EPA's Mercury Maps tool in two places (pages 67
and 93). In both places, the Guidance suggests that pulp and paper mills
are significance sources of mercury loadings due to effluent discharges.
We believe that this is an inadvertent reference, based on information
the Agency has previously corrected. Specifically, EPA's Mercury Maps
website now contains a "Note" on the treatment of pulp and paper mills
in the Mercury Maps reports.[^1] The Note was the result of discussions
and information exchanges between industry and EPA representatives on an
earlier version of the Mercury Maps tool which contained the same
inaccurate characterization of mills discharges. The Note indicates that
the earlier analysis over estimates mill mercury contributions to
watersheds and that Mercury Maps users should not rely on a national
level assessment of potential mill mercury contributions. Instead, they
should rely on actual effluent and site- specific receiving water data.

> We request that EPA remove the two references to pulp and paper mills
> in the Guidance, to be consistent with the more accurate information
> now contained on the Mercury Maps website. Thank you for your
> consideration of this matter and please call me at (202) 463-2581, if
> additional information is needed.

Sincerely,

![](media/image2.png){width="2.5416666666666665in"
height="0.7916666666666666in"}

Jerry Schwartz

Senior Director

Water Quality Programs

cc: Jim Pendergast, EPA

[^1]: http://www.epa.gov/waterscience/maps/pulpandpaper.pdf