We’re managing private forests so they work for all of us. ® 

### W ASHINGTON 

### F OREST 

### P ROTECTION 

### A SSOCIATION 724 Columbia St NW, Suite 250 Olympia, WA 98501 Tel: 360

- 352

- 1500 Fax: 36 0

- 352

- 4621

Submitted via: R10

- Public

_ Comments@epa.gov

February 4 , 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: Approv al and Promulgation of Implementation Plans; Washington: Prevention of Significant Deterioration (PSD) and Visibility Protection

Dear Mr. Hunt:

Founded in 1908, the Washington Forest Protection Association (WFPA) is a trade association representing large and small private forest landowners and managers of nearly 4 million acres of productive working forests located in the coastal and inland regions of Washington State. Our members support rural and urban communities through the sustainable growth and harv est of timber and other forest products for U.S. and international markets. WFPA’s objective is to support balanced policies at the state and national levels which create an equilibrium between equitable costs, environmental protection and long

- term regula tory certainty.

WFPA 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 Washingt on Administrative Code (WAC) 173

- 400 submitted to the Environmental Protection Agency (EPA) by the Department of Ecology on January 27, 2014.

More than half of Washington’s land base is forested, and of that about 47% are considered working forests produ cing renewable wood, energy and paper products that support our local economies. Private landowners account for more than 70% of the annual timber harvest and are therefore the largest segment of the forest products industry sector (including state and pr ivate forest lands, sawmills, pulp and paper mills, furniture manufacturing, wholesaling and port activity

. ) On a national scale, Washington mi lls produce the second highest amount of softwood lumber in the country. Washington’s forest products sector is the
thir d largest segment of our manufacturing i ndustries , and supports a total of nearly 40,000 direct jobs and 107,500 direct, indirect and induced jobs. Because many WFPA members are located in economically stressed rural communities, these family

- wage jobs help su stain the local economy, and community.• Page 2 Washington Forest Protection Association

Members of WFPA own and operate sawmills and pulp and/or paper facilities that are required to obtain air operating permits under the Clean Air Act. WFPA members have a direct interest in upholding Washington’s poli cy and regulatory approach governing biomass emissions.

WFPA has one comment on air permitting implementation issues regarding treatment of carbon dioxide
emissions from the combustion of biomass.

We understand that under the proposed approval, EPA pr oposes to retain its role as the primary authority for issuing “PSD permits” for carbon dioxide emissions solely from biomass. EPA proposed this exception due to Washington state law 70.235.020(3) which prohibits treatment of emissions from the combustion of forest biomass as greenhouse gas. Revised Code of Washington 79.02.010(7)(a) "Forest biomass" means the by

- products of: Current forest management activities; current forest protection treatments prescribed or permitted under chapter 76.04 RCW; or the by

- products of forest health treatment prescribed or permitted under chapter 76.06 RCW.

We also note that Washington’s Governor Inslee a ck no w l edges the importance of forest biomass in addressing forest health issues on federal lands, and supporting jobs and economic activity in timber dependent communities, in his August 27, 2014 announcement to Wind River Biomass Utility:

“ Enabling clean, renewable heat and power generation from forest biomass not only creates jobs and economic activity in our timber

- dep endent communities, it supports our efforts to reduce greenhouse gas emissions and increase treatment of our forested lands for health and fire reduction. ”

Comment: As a result of the Supreme Court’s decision in Utility Air Regulatory Group v. Environmenta l Protection Agency, 134 S.Ct. 2427 (2014), and the still

- pending remand of this case before the U.S. Court of Appeals for the D.C. Circuit, there is considerable confusion over the PSD program for greenhouse gas emissions. EPA does explain in the proposal that the Supreme Court ruled that PSD permits may not be triggered by greenhouse gas emissions but that greenhouse gases may be considered under the Best Achievable Control Technology (BACT) analysis if the PSD permit requirement is triggered by one of th e criteria pollutants. EPA must clearly explain in the final approval that, due to the Washington state laws referenced above concerning forest biomass, it is retaining the authority to conduct the BACT analysis for PSD permits only for biogenic greenhouse gas emissions from forest biomass and will coordinate its processing and issuance of PSD permits with the Department of Ecology. EPA must also commit to following
the agency’s existing guidance on BACT for biogenic emissions, Guidance for Determining Bes t Available Control Technology for Reducing Carbon Dioxide Emissions from Bioenergy Production (March 2011)

.

Thank you for the opportunity to comment.

Sincerely,

Cindy Mitchell
Sr. Director of Public Affairs Washington Forest Protection Association