Submitted	via:		R10-Public_Comments@epa.gov

February	6,	2015

Jeff	Hunt	

EPA	Region	10

Office	of	Air,	Waste	and	Toxics	(AWT–150)

1200	Sixth	Avenue,	Suite	900

Seattle,	WA 98101.

Attention:		Docket	ID	No. EPA–R10–OAR–2014–0755

Re:		Proposed	Rule:		Approval	and	Promulgation	of	Implementation	Plans;	Washington:	

Prevention	of	Significant	Deterioration	(PSD)	and	Visibility	Protection

Dear	Mr.	Hunt:

The	Northwest	Pulp	&	Paper	Association	(NWPPA)	appreciates	the	opportunity	to	comment	on	

the third	part	of	the	proposed	rules to	approve	revisions	to	Washington’s	State	Implementation	

Plan	(SIP)	from	updates	to	Washington’s	industrial	air	quality	regulations	contained	in	

Washington	Administrative	Code	(WAC)	173-400	submitted	to	the	Environmental	Protection	

Agency	(EPA)	by	the	Department	of	Ecology	on	January	27,	2014.	

NWPPA	is	a	59	year-old	regional	trade	association	representing	14	member	companies	and	17	

pulp	and	paper	mills	in	Washington,	Oregon	and	Idaho.	NWPPA	members	produce	over	8	

million	tons	of	paper	products	each	year	and	provide	approximately	12,000	predominantly	

union-backed	jobs	that	pay	an	average	of	more	than	$75,000	a	year,	plus	benefits.	As	one	of	

the	largest	members	of	Washington’s	forest	products	sector	(including	private	forest	lands,	

sawmills,	furniture,	wholesaling	and	ports),	pulp	and	paper	mills	contribute	to	a	total	of	

approximately	40,000	direct	jobs	and	107,500	direct,	indirect	and	induced	jobs.	Because	many	

NWPPA	members	are	located	in	economically	stressed	rural	communities,	these	family-wage	

manufacturing	jobs	help	sustain	the	local	economy,	with	each	mill	supporting	three	to	five	

additional	jobs	in	the	community.

NWPPA	represents	its	members	on	regulatory	and	legislative	issues	with	special	emphasis	on	

environmental	and	energy	policy.

Members	of	NWPPA	own	and	operate pulp	and/or	paper	facilities	that	are	required	to	obtain	

air	operating	permits under	the	Clean	Air	Act.		NWPPA members	have	a	direct	interest	in	this	

action	because	their	air	permits	could	potentially be	affected	by	adoption	of	this State	
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February	6,	2015

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Implementation	Plan.	 NWPPA	also	participated	in	and	provided	comments	during	the	

Department	of	Ecology’s	rule	making	process	on	WAC	173-400.	

NWPPA	has	two	comments	on	air	permitting	implementation	issues	regarding	treatment	of	

carbon	dioxide	emissions	from	the	combustion	of	biomass.	

Section	IV. The	EPA’s	Proposed Action,	C. Scope	of	Proposed	Action, 1.	WAC	173-400-700	

Through	173-400-750,	b. Carbon	Dioxide	Emissions	from	Industrial	Combustion	of	Biomass

Comment	1:		Please	clarify	how the	proposed	SIP	revisions	govern	whether	EPA	or	the	

Department	of	Ecology	would	prepare	a	PSD	permit	and	determine	best	available	control	

technology (BACT) when	carbon dioxide	emissions	from	industrial	combustion	of	both	fossil	

fuel	and	biomass	are	emitted	above	significance	thresholds.	EPA	should	clearly	explain	in	the	

final	approval	that	it	is	retaining	the	authority	to	conduct	the	BACT	analysis	for	PSD	permits	

only for biogenic	carbon	dioxide	emissions	from	biomass	and	will	coordinate	its	processing	and	

issuance	of	PSD	permits	with	the	Department	of	Ecology.	EPA	should	also	clarify	that	it	will	

follow	EPA’s	existing	guidance	on	BACT	for	biogenic	emissions,	Guidance	for	Determining	Best	

Available	Control	Technology	for	Reducing	Carbon	Dioxide	Emissions	from	Bioenergy	Production	

(March	2011).

Discussion:		We	understand	that	under	the	rule	proposal,	EPA	proposes	to	retain	its	role	as	the	

primary	authority	for	issuing	PSD	permits	for	carbon	dioxide	emissions solely	from	biomass

because	the	Department	of	Ecology	is	statutorily	barred	from	regulating	carbon	dioxide	

emissions	from	the	combustion	of	biomass	under	Revised	Code	of	Washington	70.235.020(3).		

The	Proposal	states	that	Department	of	Ecology	is	“prohibited	from	issuing	a	PSD	permit	

regulating	CO2 emissions.”		In	cases	where	there	are	multiple	combustion	fuels	producing	

carbon	dioxide,	we	are	unclear	as	to	the	division	of	roles	and	responsibilities	between	agencies	

for	permit	evaluation	and	issuance	for	carbon	dioxide	emissions.	 Would	the	Department	of	

Ecology	retain	permitting	authority	for	non-biogenic	carbon	dioxide	emissions?		

Comment 2:		NWPPA	supports	the	State	of	Washington’s	statutory	exemption	of	carbon	

dioxide	emissions	from	the	biomass	combustion	from	the	definition	of	greenhouse gases	in	the	

Revised	Code of	Washington	70.235.020(3).		This	statutory	provision	codifies Washington’s	

policy	and	regulatory approach governing	biomass	emissions.			 In	EPA’s	memorandum,	

“Addressing	Biogenic	Carbon	Dioxide	Emissions	from	Stationary	Sources”	from	Janet	McCabe,	

November	19,	2014,	we	appreciate	EPA’s	recognition	that	the	“use	of	waste-derived	feedstocks	

and	certain	forest-derived industrial	byproducts	are	likely	to	have	minimal	or	no	net	

atmospheric	contributions	of biogenic	C02	emissions,	or	even	reduce	such	impacts,	when	

compared	with	an	alternate	fate	of disposal.”		NWPPA	also	supports	EPA’s	plans	to	“propose	

revisions	to	the	PSD	rules	to	include	an	exemption from	the	Best	Available	Control	Technology	

(BACT)	requirement	for	GHGs	from	waste-derived feedstocks	and	from	non-waste	biogenic	

feedstocks	derived	from	sustainable	forest	or agricultural	practices.”		NWPPA	urges	EPA	to	

expeditiously complete	these revisions	to	the	PSD	rules which	will	support	the	State	of	
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February	6,	2015

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Washington’s	statutory	approach	for	biomass	emissions	and	allow	for	full	delegation	of	the	PSD	

program

Discussion:		NWPPA	wishes	to	work	with	both	EPA	and	the	Department	of	Ecology	as	both	

agencies	continue	to	issue	State	of	Washington	PSD	permits	and	we	look	forward	EPA’s	full	

delegation	of	the	PSD	program	to	the	Department	of	Ecology at	a	future	date.

Thank	you	for	the	opportunity	to	comment.		Please	contact	me	at	503-844-9540	to	answer	any	

questions.

Sincerely,

Kathryn	VanNatta

Director	of	Regulatory	and	Government	Affairs

Northwest	Pulp	and	Paper	Association