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

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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	rule s to	approve	revisions	to	Washington’s	State	Imple mentation 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	W ashington,	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	member s	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	man y 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	regulato ry	and	legislative	issues	with	special	emphasis	on environmental	and	energy	policy.

M embers	of	NWPPA	own	and	operate pulp	and/or	paper	facilities that	are required	to	obtain air	operating permits un der	the	Clean	Air	Act.		NWPPA members	have	a	direct	inter est	in	this action	because	their air	permits	could	potential ly be	affected	by adoption	of	this StateNWPPA	Comments

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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	t wo comments	on	air	permitting	implementation	issues	regarding	treatment	of carbon	dioxi de	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	fossi l 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	f or	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	PS D	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	CO 2 emissions.” I n	case s	where	there	are	multiple	combustion	fuels	producing carbon	dioxide ,	we	are	unclear	as	to	the division	of roles	and	responsibilities	between	agencie s fo r	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 c ombustion	from	the	definition	of	greenhouse gases	in the Revised	Code of	Washington	70.235.020(3) .		This	statutory	provision	codifie s Washington’s policy	and	regulatory approach governing	biomass	emis sions

. 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	bypr oducts	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	incl ude	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 compl ete the se revisions	to	the	PSD	rules which	will support	the	State	ofNWPPA	Comments

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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 Depart ment	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