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Prevention of Significant Deterioration/Title V Greenhouse Gas Tailoring Rule 

American Forest & Paper Association 

Response to EPA questions Regarding Impacts on Small Business 

The American Forest & Paper Association is the national trade association of the forest 

products industry, representing pulp, paper, packaging and wood products 

manufacturers, and forest landowners. Our companies make products from renewable 

and recyclable resources. The forest products industry accounts for approximately 6 

percent of the total U.S. manufacturing GDP, putting it on par with the automotive and 

plastics industries. Industry companies produce $200 billion in products annually and 

employ approximately 1 million people earning $54 billion in annual payroll. The 

industry is among the top 10 manufacturing sector employers in 48 states.

Of AF&PA’s 135 member companies, approximately 23 companies are considered 

small businesses per the formal government definition1

. AF&PA does not collect Title 

V permit information or potential to emit information from our members and therefore 

cannot directly answer many of the questions posed by EPA. However, we would like 

to highlight what we see as a severe impact on small facilities, largely wood products 

mills, due to the Tailoring Rule’s failure to recognize that emissions from the combustion 

of biomass are carbon neutral and should not be included in major source and 

modification thresholds. 

Carbon neutrality is universally recognized as a basic tenet of renewable energy 

and climate change policy. It is incorporated into the Intergovernmental Panel on 

Climate Change Guidance and the UNFCCC reporting protocols, which U.S. EPA uses 

to calculate its annual GHG inventory of emissions and sinks. 

Like most GHG Reporting protocols, EPA’s Mandatory GHG Reporting Rule excludes 

biogenic emissions from the threshold determination. The European Union Emissions 

Trading System and proposed climate legislation in the U.S. do not regulate emissions 

                                                           

1 Employ less than 500 people
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from biogenic sources. By including biogenic emissions in its threshold determination 

for PSD major sources, AF&PA estimates that an additional 136 wood products mills 

will be considered major sources for GHGs under PSD. If biogenic emissions are 

excluded from PSD threshold determinations, only 5 mills would exceed the 25,000 

threshold. This is an increase from 2% of member wood product mills considered major 

sources to 51%. 

EPA has ample authority to exclude CO2 emissions generated by combustion of 

biomass from the determination of whether a facility is a major stationary source or is 

undergoing a major modification for PSD purposes. In fact, EPA has repeatedly 

asserted that it has similar types of flexibility to interpret the PSD provisions of the Clean 

Air Act, including in the proposed Tailoring Rule. 

There are significant consequences should the PSD GHG Tailoring Rule not 

recognize the carbon neutrality of CO2 emissions from biomass. 

First, treating biomass-based fuels essentially the same as fossil fuels under climate 

policy would increase the adverse environmental impacts associated with fossil fuel 

use. Entities would prefer to use fossil fuels, which have higher heating values and are 

therefore more efficient in terms of energy production. Beyond GHGs, fossil fuels also 

produce more sulfur dioxide when burned than do biomass-based fuels. 

Second, failing to recognize the carbon neutrality of biomass would create substantial 

uncertainty, deterring markets for renewable energy and upsetting strategies to address 

climate change and energy security. Investors and industries planning to undertake 

investments in these areas would be paralyzed precisely at a moment when the national 

and global economies need those types of investments. 

Third, economic and job dislocation would likely result in jurisdictions that do not 

recognize biomass as carbon neutral in climate policy. EPA would be eliminating a 

potential cost mitigating compliance strategy - the use of carbon neutral biomass fuel - 

for forest products industry and other manufacturing facilities. Due to increased cost of 

compliance (and being competitively disadvantaged globally), these facilities may have 

to close and relocate to other areas outside the U.S. that do not have mandated GHG 

reduction programs or that do recognize the carbon neutrality of biomass in their GHG 

reduction programs. 

Finally, because national accounting procedures account for biogenic emissions 

separately as net emissions (and sequestration) from land use activities, counting 

emissions from the combustion of biogenic sources would result in double counting. 
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AF&PA appreciates the opportunity to submit these comments. Please do not hesitate 

to contact us with any questions. 

Contact: 

Rhea Hale 

rhea_hale@afandpa.org

202-463-2709 

Tim Hunt 

tim_hunt@afandpa.org

202-463-2588