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

WASHINGTON FOREST PROTECTION ASSOCIATION 

724 Columbia St NW, Suite 250

Olympia, WA 98501 

Tel: 360-352-1500

Fax: 360-352-4621

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: Approval 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 harvest 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 regulatory 

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 Washington 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 

producing 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 private forest lands, sawmills, pulp and paper 

mills, furniture manufacturing, wholesaling and port activity.) On a national scale, Washington mills produce 

the second highest amount of softwood lumber in the country. Washington’s forest products sector is the 

third largest segment of our manufacturing industries, 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 sustain 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 

policy 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 proposes 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 acknowledgesthe 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-dependent 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. Environmental 

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 the 

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 Best 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