AF&PA on the Issues
The forest products industry employs about 900,000 men and women and is built on principles of sustainability: producing recyclable products from a renewable resource. We are among the top 10 manufacturing sector employers in 45 states. American Forest & Paper Association (AF&PA) members manufacture essential paper and wood-based products that are used daily by people across the country and around the world — products that play an important role in literacy, education, hygiene, food safety, product marketing and protection, and home and office construction. We support market-based policies and regulations that foster economic growth, job creation, and international competitiveness in this vital sector. We believe public policies are most effective when they meet the economic needs, environmental concerns, and societal expectations of our diverse communities.
AF&PA member companies have invested billions of dollars as part of its environmental stewardship, including a 29 percent reduction in emissions of nitrogen oxide (NOx) and 53 percent for sulfur dioxide (SO2) by our pulp and paper facilities since 2000. Despite this investment, the industry faces challenges from new and existing regulations — driven by lawsuits under the Clean Air Act — that together could impose more than $10 billion in new capital obligations on the industry over the next 10 years. The cumulative burden being imposed on business is unsustainable.
Biomass for Renewable Energy
The forest products industry is the nation’s leading producer and user of carbon-neutral, renewable biomass energy. AF&PA believes market forces, not government mandates and incentives, should determine the use of wood and wood residuals for renewable energy. Woody biomass is an essential raw material for value-added forest products, such as paper, packaging, wood products, wood-based chemicals, and other innovative products. Paper and wood products manufacturing facilities account for 62 percent of the renewable biomass energy consumed by all manufacturing sectors, most of which is derived from manufacturing residuals. This process is among the most efficient in the world, using materials that would otherwise be waste to create both thermal and electrical energy, commonly referred to as combined heat and power (or cogeneration) technology.
Studies show that per ton of wood used, the paper and wood products manufacturing industry sustains nine times as many total jobs as the biomass energy sector. Accordingly, it is important for federal renewable energy policies should not require forest products manufacturing facilities to compete on an uneven playing field with their power suppliers and other energy producers for biomass fiber.
Carbon Neutrality of Biomass Energy
Paper and wood products facilities use biomass residuals from their manufacturing operations to generate bioenergy. The energy is used to make products and it provides significant greenhouse gas reduction benefits to the environment. AF&PA urges policymakers to take action that clearly recognizes our industry’s use of biomass for energy as carbon neutral.
Prior to 2010, the U.S. clearly recognized forest-based biomass energy as carbon neutral. In EPA’s Greenhouse Gas (GHG) Tailoring Rule, for the first time, no such designation was made, subjecting biomass energy used in stationary sources to Clean Air Act permit program requirements. In 2011, EPA issued a rule deferring regulation of biogenic CO2 emissions while it studied the issue and pledged to complete an accounting framework for biogenic emissions from stationary sources by July of 2014, which three years later is still incomplete.
The forest products industry is the largest producer and user of bioenergy of any industrial sector and has long-standing operations in the U.S. The creation and use of biomass energy in forest products mills is integral and incidental to the manufacture of products such as pulp, paper, packaging, tissue and wood products. Pulp mills, integrated pulp and paper mills and wood products mills convert biomass residuals to energy while manufacturing biobased products that are useful to society. This sustainable use of forest products manufacturing residuals for energy provides enormous greenhouse gas benefits by avoiding the emission of about 181 million metric tons of CO2 equivalent. This is equivalent to the emissions of about 35 million cars.
Our industry is a leader in the generation and use of renewable energy and highly-efficient combined heat and power (CHP), or cogeneration technology. Purchased energy is a major manufacturing cost for the forest and paper industry even though the industry is the largest manufacturing sector producer and user of renewable biomass energy.
Greenhouse gas regulation could increase energy costs and decrease the reliability of the electric system. As the nation confronts the challenge of upgrading its electrical transmission infrastructure, care must be taken to ensure that upgrades are based on sound economic analysis and that their costs are paid for in a fair and equitable manner.
AF&PA is pleased that the Supreme Court stayed the implementation of the CPP rule pending resolution of claims that EPA exceeded its legal authority in the way in which the rule is crafted.
Between 2005 and 2014, AF&PA members reduced their GHG emissions by 16 percent, surpassing our Better Practices, Better Planet 2020 goal of 15 percent reduction. In 2017, wanting to further improve their performance, members approved a new goal to achieve a 20 percent reduction of GHG emissions from their facilities between 2005 and 2020.
U.S. fossil fuel and industrial process emissions declined 12 percent between 2007 and 2015, largely due to market driven and voluntary reductions such as improved energy efficiency and shifts from coal to natural gas by the electric utility sector. During that same period, global emissions increased by 13 percent, and China’s rose 42 percent, according to data compiled by the European Commission. Policymakers should recognize that market driven, voluntary reductions can make regulations unnecessary.
AF&PA is a strong proponent of international efforts to suppress illegal logging because trade in illegally sourced fiber is a serious detriment to the industry’s sustainability, the environment and the global economy. An AF&PA commissioned study estimated that illegal logging cost the U.S. forest products industry some $1 billion annually in lost export opportunities and depressed U.S. wood prices.
AF&PA is working closely with a broad consensus coalition of businesses, conservation groups, and labor organizations that is calling on federal agencies to ensure successful implementation of the law. AF&PA supports adequate funding for the implementation of the Lacey Act and the phase-in of the declaration requirement to imports of composite wood products and pulp and paper.
AF&PA opposes legislative changes to the Lacey Act that would undermine the intent and effectiveness of the 2008 amendments by: limiting the application of the import declaration requirement to “solid wood,” excluding pulp, paper and composite wood imports from the key requirement of the Lacey Act; and eliminating the Lacey Act’s application to imports of forest products that were harvested, processed or traded in violation of foreign laws.
International Trade and Competitiveness
Paper and wood products exports account for about 15 percent of the industry’s annual total sales. In 2015, the industry’s global exports totaled about $30.3 billion, of which nearly $8.9 billion were exports of wood products and $21.4 billion were exports of pulp, paper and packaging
AF&PA supports trade policies that advance our industry’s strong global market position. In an increasingly globalized market, it is critical for the U.S. paper and wood products manufacturing industry to achieve unrestricted access to international markets and level the playing field among international competitors by eliminating both tariff and non-tariff barriers.
Trade agreements offer opportunities for achieving the industry’s trade and competitiveness objectives — including the speedy elimination of foreign tariffs and non-tariff barriers. We support the negotiation of trade agreements that result in commercial benefits for American companies not only by reducing tariffs and traditional non-tariff barriers, but also that provide for new rules and stronger disciplines in areas such as customs administration, intellectual property protection, the role of state owned enterprises, and greater transparency and access to the standards development process of trading partners to ensure non-discriminatory treatment of U.S. goods. We also seek strong language to eliminate illegal logging globally.
NAAQS Permitting Problems
Regulated industries are finding it increasingly difficult to expand due to out of date and unrealistic permitting requirements. EPA should address the rapidly-developing air permitting gridlock by adopting more flexible policies and allow use of more realistic emissions data and modeling tools.
The inability to permit a project hurts the competitiveness of the facility, harms product development and innovation, and can thwart environmentally beneficial projects. Local communities will miss out on new jobs and economic growth while industry sectors face the risk of becoming uncompetitive in the global marketplace of forest products.
A record 66.8 percent of paper consumed in the U.S. was recovered for recycling in 2015, and the annual paper recovery rate in the U.S. has nearly doubled since 1990. By weight, more paper is recovered from municipal solid waste streams than glass, plastic, and aluminum combined, according to EPA. Recovering paper extends the useful life of fiber and saves valuable landfill space. Paper recycling is widely accessible, with 96 percent of Americans having access to community curbside and/or drop-off paper recycling programs. The existing voluntary, market-based paper recovery system fuels innovation, creates lasting infrastructure, and enables us to make new products from paper that is diverted from the waste stream.
The U.S. Postal Service (USPS) is the essential component of a $1.4 trillion mailing industry that employs about 7.5 million Americans through which small and large businesses, nonprofit organizations, and consumers can transact business, advertise services and distribute products. Serving 153 million residents, offices and businesses across the country, the Postal Service connects people and business transactions through a sophisticated delivery infrastructure no other entity can provide. In addition, approximately one-third ($6 billion worth) of communications papers produced in the U.S. are delivered through the mail system.
Despite being a significant driver of the nation’s economic engine, USPS faces financial insolvency, even though they have implemented cost-cutting measures. Without action from Congress to address the fundamental underlying problems and to provide the flexibility to create new revenue streams, the Postal Service cannot be financially solvent. As a part of its required 10-year review the Postal Regulatory Commission the could recommend double-digit rate increases for several consecutive years, creating sticker shock which would have damaging effects on mail volume and risk mail as a competitive option for marketers and business communication. Legislators must recognize that raising rates while reducing services is counterproductive in an economy where industry and consumers are seeking faster and cheaper delivery options for communications and business transactions. These actions would simply make mail less competitive and further accelerate volume and revenue losses.
AF&PA supports legislative measures that ensure the fiscal viability of the USPS by eliminating unreasonably imposed financial obligations to the Postal Service; allows the Postal Service to innovate and develop new revenue sources; support service standards that meet the needs of the public and business customers, including continued six day mail delivery; ensures postal rate setting has checks and balances that provide price predictability for mailers and cost-control incentives for USPS; and enable mail as a cost competitive option for business communications.
Promoting Access to Paper Options for Government Programs
AF&PA believes the public should be able to choose the manner in which they receive information and services from the government and not be forced into a digital-only option. Paper and digital formats can be complementary; those who wish to receive paper-based communications and documentation should not be forced to either use digital delivery or forgo the information or service.
We support policies that recognize paper-based communications are critically important for millions of Americans. Federal agencies should not eliminate a paper option without a cost-benefit analysis, but should provide adequate public notice to people affected by a proposed elimination of paper options, allowing ample opportunity to provide input and taking public comments into account before making a final decision. Federal agencies proposing the elimination of paper options must ensure safeguards are put into place to protect personal information from identity theft or fraud before requiring a digital-only option.
The government’s rush to digitize is shortsighted, leaving many people without a viable option. Such policies discriminate against millions of Americans, many of whom are in rural communities and/or low income households — 45 percent of seniors do not own a computer and 30 percent of citizens do not have online access at home.
Recycled Content Mandates
AF&PA opposes recycled content mandates as an ineffective path to increasing paper recovery. Additionally, the distinction between pre- and post-consumer content constrains the amount of recovered fiber available for recycling and should not be used in government policies. EPA is considering changes to federal purchasing requirements that would require communication papers to have 100 percent post-consumer recycled content.
Mandating post-consumer recycled content for fiber-based products creates the misleading perception that certain types of recovered fiber are better than others. Not all types of recovered fiber are suitable for recycling into communications papers, and available post-consumer sources of recovered fiber are declining.
Rather than arbitrarily mandating 100 percent recovered content in communications papers, EPA should take a more measured approach that accounts for all of the environmental and economic consequences that mandates impose. The aim should be to increase paper recovery, and the U.S. paper industry has demonstrated its commitment its commitment by setting and working towards an industry-wide goal to exceed 70 percent recovery by 2020.
AF&PA’s comprehensive sustainability initiative — Better Practices, Better Planet 2020 — includes six measurable goals focusing on paper recovery for recycling, energy efficiency, greenhouse gas emissions, sustainable forestry practices, workplace safety, and water use. Our members have long been good stewards of our planet’s resources, and this initiative shows our proactive approach to the long-term success of our industry, our communities, and our environment. We have made great strides towards reaching the Better Practices, Better Planet 2020 goals, surpassing those for greenhouse gas emissions and workplace safety ahead of schedule.
AF&PA supports comprehensive tax reform that encourages economic growth, job creation, and the competitiveness of all U.S. businesses. Central to this is a tax system with a low corporate tax rate, support for investment in U.S. manufacturing and its global supply chain, and an international tax system that reflects a globally competitive territorial tax system.
The U.S. forest products industry — made up of both C-corporations and pass-through entities — is a significant contributor to the U.S. economy, employing nearly 900,000 men and women in above-average wage jobs, investing heavily in equipment and improvements, and exporting products throughout the world. The industry produces more than $200 billion in paper and wood products annually and accounts for approximately 4 percent of the total U.S. manufacturing GDP.
We are highly capital-intensive and have made significant investments and facility upgrades in recent years. According to the Annual Survey of Manufacturers, in 2015 the paper and wood products industry invested $12 billion in plant and equipment. Items such as recovery boilers, turbine generators, paper machines, and environmental controls are critical to maintaining technologically advanced manufacturing facilities that compete in an extremely competitive global marketplace.
AF&PA believes that a reformed tax code should be long-term, prospective, provide for a smooth transition, and not result in negative market bias.
AF&PA advocates for investments and policies that will ease congestion on roads and create safer, stronger highways. We support updating the antiquated weight limits on the interstate so that truck traffic can be reduced in a safe and efficient manner. An increase in the maximum allowable weight of six-axle semi-trailers is an effective and safe way to increase truck productivity and America's freight capacity. Technology improvements and stronger roads and bridges make it safe for each truck to carry more freight. It would also mitigate the current transportation capacity shortage that inhibits moving raw materials to mills and products to customers.
Rail customers are not receiving reliable rail service at reasonable rates. Nearly one-third of forest products facilities have access to only one rail carrier. The railroad industry has an obligation to serve its customers and the nation’s freight rail needs, but many see their monopoly status as an opportunity to charge excessive rates while providing poor service.