URGENT ACTION ALERT !

The sample letter below explains new proposed EPA regulations on industry.  There is one more week for public input!  Because Democrats did not have enough votes to pass the Cap & Trade energy bill, the EPA is stealthily imposing bureaucratic regulations that will cripple industry.  Please copy this letter and send to the EPA, and fax or email copies to our two senators, Jack Kingston, and Sanford Bishop. [contact info below]

Environmental Protection Agency

EPA Docket Center (EPA/DC)

Mailcode 2822T

1200  Pennsylvania Avenue, NW

Washington DC 20460

RE:      Docket ID No. EPA-HQ-OAR-2002-0058

            Proposed “Boiler MACT” Rule

Dear Ms Jackson:

I  live in a community that depends on  Packaging Corporation of America’s pulp and paper mill in Valdosta, GA for economic benefit, including high wage jobs with good benefits, a high tax base that supports our schools and local government, and whose purchases of wood, chemicals, and other supplies is a huge benefit to the local economy.   I am very concerned about the proposed Boiler MACT regulation that will affect the PCA mill here.  I believe this regulation would substantially increase compliance costs for the mill and could put  many jobs in the Valdosta area that depend on the  mill,  including the paper mill workers’  jobs,  at risk. 

The Boiler MACT rule is intended to address emissions of hazardous air pollutants from boilers used by big institutions, like government, hospitals and universities as well as industries, like pulp and paper, wood products, and agricultural processing.  I know that hazardous emissions need to be controlled to protect public health.  But my understanding of what EPA has proposed is that it is a rule that goes far beyond anything needed to protect health – to the point that it may not be possible for many boilers to comply with the rule requirements no matter what kind of pollution controls are installed. And that includes boilers that use “green” fuel like biomass instead of fossil fuels,  and boilers that already have very low emissions of hazardous air pollutants, many at levels that are, or are almost,  non-detectable already.

In the past 15 years, many paper mills have closed across the country due to economic conditions, including some here in Georgia.  Others in Georgia, North Florida and  many other states are barely hanging on. Some mills have been down almost as much as they have operated in the last 2 years. Even when a facility has not shut down, it may have reduced its operations, and that costs jobs at the mill and in the community.  The paper industry competes  in a global market place, and  if costs are increased unnecessarily, we cannot succeed.  My family, friends and neighbors are increasingly anxious as we worry about the future of the paper and forest products industry in our area.  Good paying jobs are hard to find, especially in the more rural areas like this, so when a paper mill, or even a paper machine, is shut down, the impact to a family due to job loss is immense.  Our communities clearly suffer when mills close – the tax base shrinks, loggers lose their primary customer and other area businesses that support the mills lose a large part of their sales. And with the loss of jobs often comes reduced health care benefits, which carries a far greater public health risk than the emissions from an already well controlled boiler.

My understanding is that EPA has issued many MACT rules affecting various manufacturing sectors, including pulp and paper.  But this time, the “rules of the game” were changed for the industrial boiler sector.  Instead of looking at the overall performance of a boiler category and the level of emissions that good performing boilers can achieve, EPA picked the best test data from different boilers all over the country for each pollutant, then retested for the “best of the best”.  A boiler that was best in controlling one emission may have been below average in controlling another, while another boiler with a different technology may have been less impressive in control of the first pollutant, but was the best for another one.  To meet all the proposed standards, it would require a string of control technologies, some that may not even be compatible with each other,  to create a hypothetical super-boiler to comply with the rule.  EPA should be setting emission standards based on what the average of the best of  actual real world boilers can meet as a viable existing unit, not cherry picking data and assuming  mix and match technologies will work. The Clean Air Act requires that the standards be achieved by the best and be achievable by the rest.  And if it was done this way,  hundreds of boilers would already be in compliance because they are the top performers.   Instead, the odds of being in compliance today with the rule as proposed are estimated at about one in a million!

I also understand that the Clean Air Act allows EPA to exempt boilers from some requirements if emissions from the boiler would not pose a risk to public health, but this exemption was not included in the proposed rule.  Why not?  If a boiler doesn’t pose a risk to public health, why regulate it further?  Facilities that can show that their emission levels are safe should not be forced to install additional, unnecessary and expensive control equipment.  Mills can’t waste money like that and expect to survive.

The proposal also creates huge hurdles for biomass boilers, with standards that are so low that they can’t even be reliably measured! These standards will result in reduced usage rates for biomass and require the use of  fossil fuels in its place. It makes no sense at all to discourage the use of clean biomass fuels in the name of  environmental improvement!  

The PCA Valdosta mill  is investing in modernization, to become more energy efficient and less dependent on fossil fuels, especially foreign oil.  Proposals like this Boiler MACT rule consume  all the available capital within companies, and put good projects that could increase efficiency on hold. The end result is mills across the nation that have  costly new controls on old boilers, instead of allowing gradual movement forward with new, efficient boiler technology.  And that makes them less cost efficient and less likely to survive.

There’s no need for this.  EPA’s proposed Boiler MACT can and should be written in a way that protects both the environment and jobs.  Revamping the selectively picked emission limits and allowing the  health risk assessment process must be part of the final rule.  We need clean air, but we also need manufacturing jobs in America.  EPA can meet its goals while preventing further paper industry job losses and avoiding unnecessary regulatory compliance costs if Boiler MACT is written based on realistic objectives for both the environmental and public health needs of our country.

Sincerely,

Address: ____________________________

                ____________________________

Xc:      Senator Chambliss

            Senator Isakson

            Congressman Bishop

            Congressman Kingston

Senator Saxby Chambliss

416 Russell Senate Office Building
Washington, DC 20510
202-224-3521
Fax: 202-224-0103

http://www.chambliss.senate.gov/

Senator Johnny Isakson

120 Russell Senate Office Building
Washington, DC 20510
202- 224-3643
Fax: (202) 228-0724

State Office: 770- 661-0999
State Fax: (770) 661-0768

http://isakson.senate.gov/

Rep. Jack Kingston  (Dist. 1)

2368 Rayburn HOB
Washington, DC 20515
202-225-5831
Fax: 202-226-2269
http://kingston.house.gov/contact/ 

Savannah: FAX: 912-352-0105

Brunswick: FAX: 912-265-9013

Valdosta: FAX: 229-247-9189

Baxley: FAX: 912-367-7404

 

Rep. Sanford Bishop  (Dist. 2)

2429 Rayburn HOB

Washington DC 20515-1002
Phone- (202) 225-3631

Fax- (202) 225-2203

http://www.bishop.house.gov/

[click on “contact Congressman Bishop” in the heading]

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Hey, Tea Parties! Wanna make a difference? See Gary North’s 8 hardcore truths.  This is what someone should have done to Jack Kingston eighteen years ago, Saxby Chambliss sixteen years ago, and Johnny Isakson eleven years ago.  Fear and Pain.  It’s never too late to start!http://bit.ly/bpUFwM

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Tea Party Caucus formed in US House of Representatives:

http://www.youtube.com/watch?v=FxUeAjALjjU

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The Grinch Who Stole Conservatism (Newt Gingrich)

http://chuckbaldwinlive.com/home/?p=1997

Newt Gingrich: The Establishment’s Conservative

http://www.thenewamerican.com/index.php/usnews/politics/2396-newt-gingrich-the-establishments-conservative?showall=1

On Gingrich – A Legacy of Surrender, by Howard Rich 7-26-10

http://blog.getliberty.org/default.asp?Display=2492

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Powerful forces are pushing a Con Con agenda.  Learn why calling a Constitutional Convention is a terrible idea: 

http://www.americanpolicy.org/more/powerful.htm

http://www.eagleforum.org/topics/concon/

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Department of Defense can’t account for $8.7 billion, 7-27-10

http://www.federalnewsradio.com/?sid=2012362&nid=35

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Stop the Mosque at ground zero 

http://www.lookingattheleft.com/2010/06/stop-the-mosque-at-ground-zero-part-ii/

“Always vote for principle, though you may vote alone, and you may cherish the sweetest reflection that your vote is never lost”.  John Quincy Adams

“Those who expect to reap the blessings of freedom, must, like men, undergo the fatigue of supporting it.” Thomas Paine