august 2010 environmental synopsis

8/9/2019 August 2010 Environmental Synopsis

http://slidepdf.com/reader/full/august-2010-environmental-synopsis 1/8 A Legislative Service Agency of the Pennsylvania General Assembly

The Chairman’s Corner Rep. Scott E. Hutchinson, Chairman

(continued on page

August 2010 Vol. 10, No. 8

Published Monthly

C JC

oint LegislativeAir and WaterPollution Control and

onservation

ommittee

In This Issue… The Chairman’s Corner .................p. 1Notes From the Director p. 2 Research Briefs ..........................p. 3-6

A Blueprint for a Green Economy

Numeric Standards for Nutrients aNew Trend?

Health Questions About LEEDCertified Buildings

Nitrogen Oxide Emissions Declining

On The Horizon p. 7 Committee Chronicles ...................p. 7

E YNOPSIS

Following a recent meeting, a majority of the Leg-islative Forestry Task Force (task force) of the Jointegislative Air and Water Pollution Control and

Conservation Commit tee urged changes to proposed U.S.nvironmental Protection Agency (EPA) regulations that

would impose strict new limits on emissions from industrial,

commercial and inst itutional boilers and process heaters– including biomass fi red boilers and heaters.Left unchanged, the proposed federal regulations, called the Boiler Maximum

Achievable Control Technology Rule or Boiler MACT Rule, could result in massivejob losses and estimated compliance costs in the billions for aumber of Pennsylvania manufacturing industries. While the foreroducts industry – a major Pennsylvania employer – would be

especially hard hit, the proposed regulations would also impactniversities, food product processors, and the chemical, metal-

working, auto, plastic and refi ning industries, just to name a fewManufacturing employers are already up against it economically

e need reasonable, realistic, science-based standards, not ir-esponsible, industry -killing standards.

After hearing testimony from several industry members, PennState University and an environmental consultant, the task force,at the behest of a majority of its members, prepared and offeredcomments to the EPA seeking changes to the Boiler MACT Rule,and encouraged other industries using such boilers to do the samefore the August 23 comment period deadline.

Among the national organizations seeking change to the rulehe American Forest and Paper Association (AF&PA) has estimatehe total capital cost of the EPA proposal to be in excess of $21illion, and as much as $6 billion to $7 billion over the next two

to four years specifi cally for the forest products industr y. According to the AF&PAthe forest products industry has lost 350,000 jobs since the beginning of 2006,and the proposed rules coupled with other EPA proposals in the pipeline couldmean the loss of “hundreds of thousands” more forest product jobs.

The National Association of Manufacturers (NAM) also expressed its oppositionthe proposal in a letter to the task force.

The most common complaints from NAM and affected employers are that theproposed emission limits are unrealistic and virtually impossible to meet, fail totake into account variables in fuels and boiler capabilities or allow for fl exible


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___________________________________________

PA is among states considering differing

versions of e-waste legislation, one

of which (House Bill 409) the Joint

Legislative Air and Water Pollution

Control and Conservation Committee

helped develop

View the Committee’s “Report on E-

Waste Recycling Programs and Policy

Options” on our website

___________________________________________

ENVIRONMENTAL SYNOPSIS / AUGUST 2010 / P. 2

OTES FROM THE D RCRAIG D. BROOKS, EXECUTIVE DIRECTOR

There are about 24 electronic products in theaverage American household. But, if you’relike many people, you also have a stockpile

of obsolete electronics stashed in a closet somewhereecause you don’t know how or where to get rid of

hem. This electronic waste or “e-waste” generallyincludes discarded consumer or business electronicequipment such as old television sets, VCR’s and DVDlayers, computers and monitors, game consoles,

stereos and cell phones.E-waste is one of the fastest growing waste

streams in the world. In 2004, there were 183illion computers sold

globally. It is estimatedhat by the end of 2010,here will be 716 millionew computers in use.i th an average l i fe-

span of just two years,illions of tons of e-wasteill be generated over a

elatively short period ofime. While many areempted to discard theseaterials alongside their

everyday trash, e-wastecontains some potentiallydangerous and toxic materials that require specialandling. Some common hazards in e-waste include:ercury, which is used in fl at panel monitors; lead,sed in TV and computer cathode ray tubes; bromi-

ated fl ame retardants, which are used in plastic casesand cables; and cadmium, which was used in older,echargeable cell phone batteries.

To help keep e-waste out of landfi lls, incinera-ors and your closet, states and local governmentsare developing legislation to make sure e-waste isandled properly through permitted treatment, stor-

age and disposal facilities. Proposed laws also aimo guarantee that new products are designed andanufactured with fewer toxic materials.

E-waste recycling laws differ from state to state bgenerally fall into two categories: producer resposibility and advance recovery fee. Under producake-back programs (also called extended producesponsibility), manufacturers are responsible for taing back discarded electronics and establishing troper recycling of the e-waste. Manufacturers oftuild in a recycling fee with their products. Propecycling means collecting e-waste in the manufacter’s own take-back program or in coordination wa certifi ed collection and recycling organization. does not include shipping the waste to developin

countries. Because surograms make the man

acturers accountable fold products, take-bacalso encourage compies to design produc

hat use fewer toxic sustances.

The advance recoveee programs shi f t thecycling burden frohe manufacturer to tconsumer. Under thype of program, wheyou purchase a new fl

screen TV, for example, you would pay a nonrefunable recycling fee somewhere between $4 and $1dollars. These programs are often criticized becauof the upfront fees associated with the collectioecycling and disposal of the waste and the lack incentive to entice manufacturers to reduce their uof hazardous materials.

Currently, the Environmental Protection Agenand the consumer electronics industry sponsor a prgram call “Plug-in to eCycling” to make it easier donate and recycle electronics at local, regional aational collection and recycling facilities. Last yeahe program recycled or reused more than 47 milliounds of computers, cell phones and televisions


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SEARCH BRIEFS

Each month, the committee’s staffresearches and prepares a number of

“briefs” on several topics relevant to the JointConservation Committee’s mission.

Very often, these briefs include references toreports and further research on the topics sothat readers may pursue issues on their own.

Report: Green Economy, Jobson Upswing in Rocky MountainStates-- Tony M. Guerrieri, Research Analyst

A

report by Headwaters Economics compareshow Colorado, Montana, New Mexico,Utah and Wyoming – fi ve states with vast

traditional and clean energy resources – are takingadvantage of clean energy opportunities to create

jobs.The report, “Clean Energy Leadership in the

Rockies: Competitive Positioning in the Emerging Green Economy” , defi nes the “green economy” asbusiness and people that provide products, servicesand knowledge associated with alternative energyproduction, energy effi ciency, recycling and cleanupof environmental pollut ion. It concludes with fi vekeys to success for the states to further benefi t fromthe emerging green economy while measuring thelikelihood that each state’s policies will promote futuregrowth and investment.

Using a conservative measurement of greenjobs, the report found that employment in the greeneconomy has grown signifi cantly faster than totalemployment. In New Mexico, for example, the num-

ber of overall jobs in 2007 was 13 percent greater than in 1995, compared to 62 percent growth in thegreen jobs sector. Looking at the fi ve-state region,from 1995 to 2007 total job growth was 19 percent,while job growth in the green economy was 30 per-

cent. Nationwide, jobs overall grew by 10 percent,compared to green job growth of 18 percent from

1995 to 2007.Colorado’s green economy led the region withthe most clean energy-related jobs (in number andas a percentage) as well as green business estab-

lishments. In 2007, the fi ve states supported 3,567green enterprises with 50 percent based in Colorado(1,778 green businesses). New Mexico and Utahtied for second in the number of green businesses,with 16 percent each (577 and 579 respectively).Montana had 11 percent (408), and Wyoming sixpercent (225).

he report also measured private and publinvestment for the fi ve states. In 2008, the regioattracted more than $500 million dollars in cleaenergy-oriented venture capital, a 10-fold increascompared to 2000 levels. When looking at pubfunding from competitively-awarded federal stimulgrants by the U.S. Department of Energy, Coloradranked 15th among the 52 states and territorieUtah and New Mexico fell toward the middle of thpack, ranked 30th and 37th, while Wyoming anMontana ranked 49th and 52nd respectively.

enewable energy production is growing in afi ve states, and according to the report, there is evereason to expect continued rapid expansion. Amonthe fi ve states, Montana and Wyoming stand out ftheir wind and geothermal potential, Utah for solaand geothermal, and Colorado and New Mexico fstrength in all three. Recent data from the wind indu

try, for example, shows that installed wind capaciamong the fi ve states increased by 3,000 megawasince 1999, with more than two-thirds of that increaoccurring between 2006 and 2009.

___________________________________________

The report lists five keys to success in building a green economy that could berelevant in other states across the natio

___________________________________________

On a more cautionary note, the report found auneven record for how the fi ve states are pursuing e

ergy effi ciency, a necessary, cost-effective part of anlong-term economic strategy. Each state has a mixerecord in terms of policy commitments to reducing e

ergy consumption. None of the states, for exampspend money from their own budgets (e.g. other thafederal funds) on state transit, nor do they mandacoordinated land use and transportation planning.

he repor t concludes with fi ve keys to successneeded for the region to foster continued growth.These keys could well be applied in other states awell. The keys to success are:

1) Strategically Pair Incentives with Clear PolicGoals. Progress depends on a smart mix of appr



priate incentives and regulations, such as renewableportfolio standards with meaningful targets and com-

pliance strategies.

2) Encourage and Capture Large-Scale Invest-

ment. To attract growing private investment andbillions of federal dollars, states must have a mix ofpolicies, incentives, and proven development exper-tise.

) Cultivate a Well-Resourced Business Environ-

ment. Innovative companies require skilled workers,research institutions, and trained workers.

4) Provide Leadership. Demonstrated commit-ment to and understanding of the clean energyeconomy on the part of state leaders is a key elementin attracting growth.

5) Overcome Limited Infrastructure Capacity. Tofully cultivate their renewable energy resources, thefi ve states must overcome an inadequate transmissiongrid.

eadwaters Economics is a Bozeman, Montana-

based nonprofi t research group focused on landmanagement decisions in the West. The full report,state fact sheets, and state-by-state comparisons canbe found at: http://www.headwaterseconomics.org/greeneconomy/CleanEnergyLeadership.pdf.

EPA Proposal on Nutrients inFlorida Waters Could Set Trend-- Craig D. Brooks, Executive Director

W

hen the Environmental Protect ion

Agency (EPA) proposed limits for phos-phorus and nitrogen in Florida waters,it marked the fi rst time the federal government hasstepped in to impose numeric standards for nutrientswhen a state has failed to do so. But it may not bethe last. The agency is already under the threat ofa lawsuit by environmental organizations seekingfederal action to set standards for oxygen-depletingnutrients for waters in Wisconsin, and other groupshave petitioned EPA to set water quality standards for nutrients in all navigable waters of the United Statesthat lack approved standards.

he proposed nutrient water quality criteria for Florida would set a series of numeric limits for phos-

phorus and nitrogen pollution in the state’s lakes,rivers, streams and canals.

Nutrient standards such as these would meansignifi cant changes in the way wastewater treatmentfacilities operate and how farms handle fertilizer and manage runoff from their fi elds. According toEPA, the state would have to impose permit limitsthat would require water treatment plants to use ad-

vanced treatment methods, such as biological nutriremoval, as several systems in Florida have alreadone. The proposed nutrient rule would also in

duce a new regulatory process for setting standafor water quality improvements in impaired watewhich EPA called “restoration standards”. This

proach would allow Florida to meet interim milestoas it attempts to restore impaired waters to their designated uses. The state could also adopt inte

less-stringent designated uses and criteria until gocould be reached.

s for nonpoint sources, EPA has suggested tfarmers would be asked to limit fertilizer applicatto “agronomically necessary” amounts, to insfencing to keep cattle out of streams and providealternative water supply, or to plant vegetation buffer str ips separating fi elds from water courses

__________________________________________

The EPA action in Florida may become template to establish limits on fertilize

and sewage treatmentin other states __________________________________________

he Florida action is the result of a federal consdecree that sett led a lawsuit fi led by environmengroups. The agreement requires EPA to devestandards for Florida water during the next two yeaThis case may be used as a template to establish limon fert ilizer and sewage treatment in other states

Nutrients such as phosphorus and nitrogen fl from stormwater runoff, crop fertilizers and livesto

manures. High nitrogen and phosphorus loadincause harmful algal blooms, reduced spawngrounds and nursery habitats for fi sh, and oftenareas where there are no limits, water “dead zonare created. The algal blooms block sunlight agrowth of underwater vegetation. Algal blooeventually die off and consume dissolved oxygfrom the water column. This results in a reductionfi sh diversity and populations.

PA has relied on states to develop water quastandards for nutrients. However, the agency nothat 25 states have no standards for nutrients.

cause of these numbers, EPA is likely to take actin other states.PA agreed to establish fi nal standards for Fl

da’s lakes and fl owing waters by October 2010 afi nal standards for the state’s estuarine and coaswaters by January 2011.

nformation on Florida’s proposed nutrient st

dards is available at http://www.epa.gov/wascience/criteria/nutrient/nitgreport.pdf and http:www.epa.gov/oig/reports/2009/20090826-090223.pdf.




LEED Buildings Are NotNecessarily Less Toxic-- Tony M. Guerrieri, Research Analyst

Evironmentally friendly, energy-effi cientuildings have gone mainstream. As

with recycling, organic food and hybridcars, “green” buildings are becoming more com-

onplace and desirable, springing up around the

country. The success of the green building is partlyecause of the U.S. Green Building Council’seadership in Energy and Environmental Design

(LEED) standard, which cert ifi es a building’s greenfeatures and performance.

The public assumes that LEED certifi ed buildingsare not only good for the environment, but good for those occupying them. But that is not necessarily so,according to a report by the Connecticut-based Envi-

onment and Human Health, Inc. The report, “LEED Certifi cation: Where Energy Effi ciency Collides with Human Health” , says that the voluntary rating systemrovides a false sense of security regarding the health

and safety of its certifi ed buildings.

The report comes as municipalities and states areincreasingly incorporating LEED criteria into their localuilding codes. Since the rating system for new

construction began in 2000, there have been roughly5,000 LEED projects in all 50 states.

____________________________________________ The report lists overlooked health threats

in the LEED certification in two areas:indoor air quality and drinking water

____________________________________________

The LEED certifi cation process offers a total of110 points in seven categories aimed at promotingsustainability. The LEED categories include energyand atmosphere savings, sustainable sites (minimizingimpacts on ecosystems), improved indoor environmen-

tal quality, materials and resources, water effi ciency,innovation in design, and regional “bonus” credits.

According to the report, the points are heavilyweighted toward energy effi ciency and clean energyand not enough toward health protection, skewing

green-design criteria. The LEED program for “newconstruction and renovation” considers human healthwithin its “indoor environmental quality” category,which is allotted 15 points out of a possible totalscore of 110. Thus, human health concerns constituteonly 13.6 percent of the total possible award.

In the report, the Environment and Human Healthesearchers identifi ed several health threats that areoverlooked by the LEED rating system. These healththreats fall into two different categories: indoor air

quality and drinking water.The report contends that exposure to certain bui

ing materials can cause health problems. The repgoes on to list fi ve indoor air quality health threats thit says have been neglected in the LEED rating systeormaldehyde; tobacco smoke; particulates; pesticidand fl ame retardants. For example, carpet, adhesivepholstery, pressed wood, pesticides and cleaning

fl uids can give off volatile organic compounds (VOC

including formaldehyde. According to the report, hiconcentrations of VOCs can cause cancer.Concerns with drinking water include plastics

isphenol-A, PVC and phthalates (used in fl oor awall coverings), and perfl uorooctanoic acid. Wha building can earn points for reducing water useand conservation of energy necessary to acquire adistribute it, there is nothing in place to address tquality of the water used in LEED certifi ed building

According to the report, another concern is thntil recently, the board of the Green Building Cou

cil included not a single health expert. The board

dominated by developers, engineers, chemical aaterials manufacturers, and architects. Currently, j

one director among 25 has formal medical or tox

cological training – an imbalance, the report asserefl ected in LEED’s present priorities of energy cons

vation, site planning, and design.

The report recommends that numerous changes ade to the Green Building Council’s LEED progra

hat will encourage it to become more health prot

ive. The recommendations include:

• Simplify the LEED scoring system within ca

egories. Rather than issuing awards of “silver,” “golor “platinum” certifi cation, the council should requerformance within each category on a 0 to 100

scale, correcting what the report calls a “common m

impression that certifi ed LEED buildings perform win al l categories.”

• Diversify certifi cation categories into healtand other areas.

• Include indoor air and water quality testin• Include more health and environmental scien

experts on the Green Building Council’s board.• Increase the use of building products mad

r om safe chemicals.

• Encourage federal testing of chemicals useduilding products.

Environmental and Human Health, Inc. is a norofi t organization composed of doctors, public hearofessionals and policy experts who specialize iesearch that examines environmental threats to humealth. The report is available at: http://www.eh

org/reports/leed/LEED_report_0510.pdf.



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ailed hard copy to an e-mailed version, please contact Lynn Mash in the committee offi ceeither at 717-787-7570, ext. 10 or e-mail Lynn at [email protected] requesting toe removed from the mailing list and added to the e-mail list. Remember to provide your

e-mail address.Readers are also reminded that the ynopsis is available on the committee website

each month after the ynopsis’ print ing. The website address is http://jcc.legis.state.pa.us.

EPA Reports Drop in NitrogenOxide Emissions in NOx SIP CallStates-- Craig D. Brooks, Executive Director

E

missions of nitrogen oxides in Eastern,Southern and Midwestern states declinedfi ve percent between 2007 and 2008,

according to a report by the Environmental Protec-

tion Agency (EPA). The 20 states and the Districtof Columbia that are subject to EPA’s NOx BudgetTrading Program (NBP) emitted 481,420 tons ofnitrogen oxides in 2008, nine percent below theamount budgeted for the program and fi ve percentless than in 2007.

According to the report, “The NOx Budget Trad- ing Program: 2008 Highlights” , emissions of nitro-

gen oxides have declined 62 percent since 2000,when the trading program was implemented, and 75percent since 1990, when the Clean Air Act was lastamended. Ohio, Pennsylvania, Indiana, Kentuckyand West Virginia have reported the greatest decreas-

es since 1990.

____________________________________________

Pennsylvania is one of the statesreporting the greatest decreases in

nitrogen oxide emissions since 1990 ____________________________________________

The NBP was established through the NOx State

Implementation Plan Call (SIP Call) as a regional cap-

and-trade program to reduce the regional transport ofnitrogen oxide emissions from power plants and other large combustion sources in Eastern and Midwesternstates during the high ozone season from May 1through September 30. As a group, the participatingstates cannot exceed the cap, and each individualsource cannot emit more than the allowances it holdsfor compliance. Sources may sell or bank (save)

excess allowances if they reduce emissions and hamore than they need, or purchase allowances if thare unable to keep emissions below their allocatebudget. The cap is intended to lend stability andpredictability to the allowance trading market andprovide regulatory certainty to affected sources.

Nitrogen oxides react with volatile organic co

pounds in the presence of sunlight to form ground

level ozone. According to the report, 85 percentof the areas in the 20 states that had exceeded thair quality standards for ozone are now in complance. Only one area in Georgia has seen its ozoconcentrations increase since the program’s inceptiwhile just one other area, in Alabama, has shown improvement. The standard, set in 1997, is .08 paper million averaged over eight hours.

Of the 2,586 emissions sources covered by thtrading program in 2008, the report highlights thfollowing results:

• 88 percent of all entit ies regulated by the N

were electric generation units;

• 14 states and the District of Columbia hademissions below their allowance budgets;

• the average NOx emission rate for the 10highest electric demand days ( as measured by meg

watt hours of generation) consistently fell every year the NBP; and

• there has been a continuous trend of near-perfect compliance since the start of the program 2003 (only two units were out of compliance by atotal of 63 tons, and 189 allowances were retired penalty).

On May 1, 2009, the NBP was replaced bythe Clean Air Interstate Rule NOx Ozone SeasonTrading Program, which requires emission reduc-tions from affected sources in an expanded geo-

graphic area. Final documents and highlights ofkey results of the program are contained in theeport which can be accessed at: www.epa.gov/airmarkets/progress/nbp08.html.



ON THEHORIZON . . . A LOOK AT UPCOMING EVENTS

Monday, September 27, 12 noon, Room G50 Irvis Office Building, Capitol Complex, Harrisburg, PA – n vironmental Issues Forum – Matt Smith, Vice-president for Forest Operations for Finite Carbon, a Pennsyl

vania-based forest carbon development company, will speak about the carbon market and how to create an

onetize carbon credits.

Please call the Committee office at 717-787-7570if you plan to attend the Environmental Issues Forum.

MMITTEE RONICLES . . A REVIEW OF SOME

MEMORABLE COMMITTEEEVENTS

ans of the ABC TV show Extreme Home Makeover may want to scan the “extras” in an upcoming show familiar faces. The staff of the J oint Legislative Air and Water Pollution Control and Conservation Committee (Comittee) was among the many volunteers on the set when the show came to Tilden Township, Berks County earlthis month.

As the accompanying photos show, Executive Director Craig Brooks and staffers Lynn Mash

(photo at left), as well as Tony Guerrieri (right)

and Geoff MacLaughlin (left), flanking Brooks

(back to camera) in photo at bottom left, donned

the show’s volunteer t-shirts and hard hats as part

of the “Urban Fairy Tale” episode.

In one week, volunteers led by the Berks

Homebuilders Association demolished a nearly

unlivable farmhouse and built a brand new

English cottage-style home (photo at top right) complete with windmill, solar panel and gazebo (photo at bottom

right), as well as “critter cottages” for the family’s farm animals for single mother Trish

Urban and her one-year-old daughter Cora. Urban

lost her husband to a congenital heart condition just

hours before giving birth to Cora in February 2009.

The Committee staff was invited to volunteer

by the PA Recycling Markets Center which helped

to provide “green” materials and recycled building

products for the project, as well as collecting and

separating recyclables and trash on the set.

The episode is expected to air in late September

or early October.




C JC

oint LegislativeAir and WaterPollution Control and

onservation

ommittee

How toContact

The JointConservationCommittee

Phone:717-787-7570

Fax:717-772-3836

Location:Rm. 408, Finance Bldg.

Internet Website:

http://jcc.legis.state.pa.us

Mail:oint Conservation Committee

PA House of RepresentativesP.O. Box 202254Harrisburg, PA 17120-2254

alternative methods of compliance, and will result in unnecessary massive jobosses and industry closings. The standards would also require the addition ofultiple controls and complex monitoring in many cases.

In testimony before the task force, Fred Osman, a professional engineer andowner of Osman Environmental Solutions, an environmental consulting fi rm, said theegulations are just one of seven regulatory programs EPA has proposed in the pastwo months that “could have major implications for the use of wood or wood wastein combustion processes.”

Carl Webb, plant engineering manager for Wood-Mode, Inc., a Kreamer, Sny-

der County-based leading national manufacturer of custom cabinetry, told the taskorce that the cost of control equipment to meet the regulations would be as muchas $2 million, while building a new boiler would be at least another $2 million to$2.5 mil lion. Webb added that just a few years ago, the company had as manyas 2,300 employees, but now has approximately 1,200, and consumes half of theardwoods board feet it consumed two years ago. Said Webb about the pro-

osed rules, “…if not checked and more reasonable considerations made, compli-

ance for us will be very prohibitive. The cost of compliance for several woodworkingindustry companies will be too great. More companies will be forced to close their doors or move off shore.”

_____________________________________________________________________

“…incorporate sustainable approaches that protect theenvironment and public health while fostering economic recovery

and jobs within the bounds of the law.” – House Resolution 879 _____________________________________________________________________

Webb’s comments were echoed by representatives of Domtar, which operatesan environmental award-winning paper mill in Johnsonburg, Elk County that employs

ore than 370 people. The company has seen cost estimates of between $10 mil-

ion to $20 million in controls and modifi cations to its two boiler units to comply withhe proposed rule changes.

Finally, Rhett McLaren, an environmental compliance specialist with Penn Stateniversity, estimated that changes the university would have to make at its two steam

lants would carry life cycle costs of between $450 million and $460 million.

Because of the serious implications of the proposed regulations, I am cosponsor-

ing House Resolution 879, introduced by Forestry Task Force member Rep. Garyaluska (D-73) and cosponsored by task force member Rep. Kathy Rapp (R-65). The

esolution memorializes EPA to revise the proposed regulations to: “Use a method toset emissions standards that is based on what real-world best performing units canachieve…and that refl ects the variability that occurs in real-world, best performingoilers.”

The resolut ion also calls on EPA to specifi cally revise its approach for biomassoilers so that the boilers are not penalized because they start with cleaner fuel, andave an emission baseline that is very low compared to other fuels.

I question why Pennsylvania and the federal government would offer incentiveso develop the biomass industry because it is sustainable, renewable, and a cleaner alternative to traditional fossil fuels, only to see EPA then try to decimate a growthindustry with unreasonable infl exible emissions limits, so low that they would be virtu-

ally unachievable for biomass powered boilers.The companies that our Forestry Task Force heard from are responsible citizens

who are already meeting or exceeding environmental standards and constantly look-

ing for reasonable ways to economically improve their environmental performance.he Boiler MACT rules as presently constituted are unreasonable, and are part of

a tsunami of EPA regulations which will serve only to destroy jobs and close downusinesses already on the edge.

august 2010 environmental synopsis

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