boiler mact support letter
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September 6, 2011
The Honorable John A. BoehnerU.S. House of Representatives
1011 Longworth House Office BuildingWashington, DC 20515
The Honorable Nancy PelosiU.S. House of Representatives235 Cannon House Office BuildingWashington, DC 20515
The Honorable Harry M. ReidUnited States Senate
522 Hart Senate Office BuildingWashington, DC 20510
The Honorable Mitch McConnellUnited States Senate317 Russell Senate Office BuildingWashington, DC 20510
Dear Speaker Boehner; Minority Leader Pelosi; Majority Leader Reid; Minority Leader McConnell:
We are writing to express our united and strong support for H.R. 2250 and S. 1392, the EPARegulatory Relief Act of 2011, bipartisan legislation to address the serious concerns that remainwith EPAs BoilerMACT rules. As they exist today, the final Boiler MACT rules will have seriouseconomic impacts on a vast array of facilities across the industrial, commercial and institutionalsectors. These rules place at risk tens of thousands of high-paying manufacturing jobs that ournation cannot afford to lose.
As finalized, the Boiler MACT rules are unaffordable, just as the proposed rules were. The rules arenot achievable for real-world boilers across the range of fuels and operating conditions. EPA alsohas created a presumption that materials commonly used as fuels are wastes subject to theextremely costly and stigmatizing incinerator standards. This would not only impose billions ofdollars in unreasonable costs, but it also would cause millions of tons of valuable materials to be
diverted to landfills and replaced with fossil fuel a bad result for the environment.
As EPA has acknowledged, the rules were finalized with serious flaws because EPA was forced tomeet a strict court-ordered deadline. The final Boiler MACT rule alone would cost over $14 billion incapital for the manufacturing sector, plus billions more in annual operating costs. Complying withthe incinerator standards could cost several billion dollars more in capital.
Legislation is needed to resolve serious uncertainties and vulnerabilities, including to:
ensure the rules are stayed for an adequate and certain period, as EPAs currentadministrative stay is being challenged in court;
allow EPA adequate time to re-propose the rules and get them right, including time for
stakeholders to conduct more emissions testing and to avoid mistakes that occur whenrulemakings of this scope and importance are rushed and become vulnerable to legalchallenge;
provide direction and support for EPA to use the discretion it already has under the Clean AirAct and Executive Order 13563 to add flexibility and make the rules achievable;
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clarify that using non-hazardous materials as fuels does not result in boilers being treated asincinerators; and
give facilities more time to comply with the complex and capital-intensive requirements of therules.
If enacted, the EPA Regulatory Relief Act will provide the much-needed certainty and time for EPA
to get the rules right and for businesses that will be investing billions of dollars to rationally plan forthe capital expenses. This legislation will preserve jobs and the competitiveness of the U.S.manufacturing sector while protecting the environment.
We urge you to pass this important legislation as soon as possible and send it to the President forhis signature.
Sincerely,
A/C Power ColverAbitibiBowaterAlabama Forestry AssociationAlabama Pulp & Paper CouncilAllegheny Hardwood Utilization Group, Inc.American Architectural Manufacturers AssociationAmerican Chemistry CouncilAmerican Coatings AssociationAmerican Coke & Coal Chemicals InstituteAmerican Composites Manufacturers AssociationAmerican Fiber Manufacturers AssociationAmerican Forest & Paper AssociationAmerican Foundry SocietyAmerican Frozen Food Institute
American Home Furnishings AllianceAmerican Loggers CouncilAmerican Municipal PowerAmerican Petroleum InstituteAmerican Sugar Cane LeagueAmerican Wood CouncilAmerities Holdings LLCAnthony Liftgates, Inc.APA The Engineered Wood AssociationAppleton Papers Inc.APUs by Rex, LLCArcher Daniels Midland Company
ARIPPAArkansas Forestry AssociationArkansas State Chamber of CommerceAssociated Industries of Arkansas, Inc.Associated Industries of Vermont
Association of American RailroadsAssociation of Independent Corrugated
ConvertersAtlantic Wood Industries, Inc.Barge Forest Products Co.Beet Sugar Development FoundationBelden Brick CompanyBelimed, Inc.Bennett Lumber CompanyBerco, Inc.Biomass One, LPBiomass Power AssociationBlue Bell CreameriesBlue Ridge Paper Products
Boise Cascade, LLCBoise Inc.Brick Industry AssociationBusiness Council of AlabamaBusiness RoundtableCahaba Timber Co.California Forestry AssociationCalifornia League of Food ProcessorsCalifornia Metals CoalitionCanyon Creek LoggingCarolina Cotton Works, Inc.Cement Kiln Recycling Coalition
Chaney Lumber Co., Inc.Charles Ingram Lumber Co.Coast Wood Preserving, Inc.Coastal Plywood CompanyCollins Pine Company
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Colorado Association of Commerce & IndustryComposite Panel AssociationConstruction Materials Recycling AssociationCorn Refiners AssociationCouncil of Industrial Boiler OwnersCresote Council
Decker Energy International, Inc.Dietz & Watson, Inc.Domtar CorporationDouglas County Forest ProductsEastman Chemical CompanyEaton CorporationElectric Mills Wood PreservingEmpire State Forest Products AssociationEvergreen PackagingFibrekFinch Paper LLCFlakeboard AmericaFlambeau River PapersFlorida Forestry AssociationFlorida Pulp and Paper AssociationFlower City Tissue Mills Co., Inc.FMC CorporationForest Landowners AssociationForest Resources Association Inc.Forging Industry AssociationFowler Post Co, Inc.Fox River Fiber CompanyGenesee Power Station LP
George A. Whiting Paper CompanyGeorgia Association of ManufacturersGeorgia Paper & Forest Products Association, Inc.Georgia-Pacific LLCGlatfelterGliers Meats, Inc.Green Diamond Resources CompanyH. W. Culp Lumber Co.Hardwood FederationHardwood Manufacturers AssociationHardwood Plywood and Veneer AssociationHarrigan Lumber Co., Inc.
Hawaii Forest Industry AssociationHesse and Sons Dairy LLCHood Industries, Inc.Idaho Forest Group
INDA, Association of the NonwovenFabrics Industry
Indiana Hardwood Lumbermens AssociationIndustrial Energy Consumers of AmericaIndustrial Fastener InstituteIndustrial Minerals Association - North America
Innovative Pine Technology Inc.InterforInternational Falls Chamber of Commerce (MN)International PaperJ.T. Fennell Company, Inc.JELD-WEN, Inc.Jordan Lumber & Supply, Inc.Kansas City Power & LightKapstone Paper and Packaging CorporationKentucky Forest Industries AssociationKercher Industries, IncKitchen Cabinet Manufacturers AssociationKoppers Inc.Lake States Lumber AssociationLand O Lakes Wood Preserving Co.Langdale Forest Products Co.Lanse Warden Electric Company, LLCLeggett & Platt, IncorporatedLongview Fibre Paper and Packaging, Inc.Louis Dreyfus Agricultural IndustriesLouisiana Farm Bureau FederationLouisiana Pacific CorporationLouisiana Pulp and Paper Association
LyondellBasell IndustriesMaine Pulp & Paper AssociationManufacture AlabamaManufacturers and Chemical Industry Council
of North CarolinaMaple Flooring Manufacturers AssociationMaxi-Seal Harness Systems, Inc.McShan Lumber Company, Inc.MeadWestvacoMelrose Timber Company, Inc.Metal Treating InstituteMetals Service Center Institute
Michigan BiomassMichigan Forest Products CouncilMinnesota Chamber of CommerceMinnesota Forest IndustriesMission Plastics North
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Mission Plastics of ArkansasMississippi Manufacturers AssociationMissouri Forest Products AssociationMotor & Equipment Manufacturers
AssociationMount Vernon Mills, Inc.
Muscatine Foods CorporationNational Association for Surface FinishingNational Association of ManufacturersNational Association of Trailer ManufacturersNational Concrete Masonry AssociationNational Council of Farmer CooperativesNational Council of Textile OrganizationsNational Federation of Independent BusinessNational Lumber and Building Material
Dealers AssociationNational Oilseed Processors AssociationNational Solid Wastes Management
AssociationNational Spinning CompanyNC Association of Professional Loggers, Inc.Neenah Paper Inc.Nevada Manufacturers AssociationNew Hampshire Timberland Owners
AssociationNippon Paper Industries USA Co.Nisus CorporationNORA, An Association of Responsible
Recyclers (formerly the National Oil
Recyclers Association)North American Die Casting AssociationNorth American Wholesale Lumber
AssociationNorth Carolina ChamberNorth Carolina Forestry AssociationNorthwest Pulp and Paper AssociationOhio Chamber of CommerceOhio Forestry AssociationOhio Manufacturers' AssociationOhio Municipal Electric AssociationOhio Willow Wood Company
OMNOVA Solutions, Inc.Oregon Forest Industries CouncilOwens-Illinois, Inc.Pacific Wood LaminatesPackaging Corporation of America
Page & Hill Forest Products Inc.Partnership for Affordable Clean EnergyPellet Fuels InstitutePennsylvania Business CouncilPennsylvania Chamber of Business
and Industry
Pennsylvania Forest Products AssociationPennsylvania Manufacturers' AssociationPeterson Mfg. Co.Pile Driving Contractors AssociationPiney Creek LPPlum CreekPort Townsend Paper CorporationPortland Cement AssociationPossum Tree FarmPotomac Supply CorporationPPG IndustriesPrecision Machined Products AssociationPrecision Pulley & IdlerPrince Manufacturing CorporationRailway Tie AssociationRex Lumber, LLCRhodia, Inc.River Trading CompanyRock-Tenn CompanyRosboro LLCRoseburg Forest Products CompanyROW, INC.Roy "O" Martin Lumber Company, LLC
Rubber Manufactures AssociationRudd Company, Inc.S.I. Storey Lumber Co., Inc.Sage Automotive InteriorsSappi Fine Paper North AmericaSauder Woodworking Co.Scotch Plywood Company, IncSeymour Manufacturing Co., Inc.SierraPine LimitedSmith Street MillSociety of Chemical Manufacturers
and Affiliates
South Carolina Forestry AssociationSouth Carolina Pulp and Paper
Association (SCPPA)South Carolina Timber Producers AssociationSoutheast Wood
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Southeastern Lumber ManufacturersAssociation
Southern Appalachian Multiple-Use CouncilSouthern Forest Products AssociationSouthern Pressure Treaters' AssociationSP Newsprint Co.
States Industries, LLCSteel Manufacturers AssociationStella-Jones CorporationStreator Dependable Mfg. Co.Sunbury Textile Mills, Inc.Tegrant CorporationTen-Tec, Inc.Tennessee Chamber of Commerce & IndustryTennessee Forestry AssociationTennessee Paper CouncilTexas Association of ManufacturersTexas Forestry AssociationTextile Rental Services AssociationThe Association for Hose & Accessories
Distribution (NAHAD)The Business Council of New York State, Inc.The Carpet and Rug InstituteThe Dow Chemical CompanyThe International Association of Machinists
and Aerospace WorkersThe Oeser CompanyThe United Brotherhood of Carpenters and
Joiners of America
Thilmany PapersThomasson CompanyThompson Industries, IncTimber Products CompanyTMATolleson Lumber CompanyTradewinds International Inc.Treated Wood Council
Tri-State Generation and TransmissionAssociation
TrueGuard - wood preservationU.S. Beet Sugar AssociationU.S. Chamber of CommerceUniboard USA LLC
Unifi Manufacturing Inc.USA Rice FederationVector Tool and EngineeringVerso Paper Corp.Virginia Chamber of CommerceVirginia Forest Products AssociationVirginia Forestry AssociationVirginia Manufacturers AssociationWashington Contract Loggers
Association, Inc.Water Treatment Services Inc.Wausau PaperWebb Consultants, Inc.WEBB Furniture Enterprises CorpThe Westervelt CompanyWeyerhaeuser CompanyWindow and Door Manufacturers AssociationWisconsin Manufacturers & CommerceWisconsin Paper CouncilWood Machinery Manufacturers of America
cc: The Honorable Fred UptonThe Honorable Henry Waxman
The Honorable Barbara BoxerThe Honorable James InhofeUnited States SenateU.S. House of Representatives