4 The record articles

Forest Products Industry Environmental Updates

Posted: October 6th, 2021

Authors: Anna R. 

ALL4 has a long history of working with the forest products industry and participating in various industry associations to stay on top of the latest environmental policy and regulatory activities affecting our clients. We provide some updates on environmental activity affecting the forest products industry below.


The reconsideration of the fine particulate matter (PM2.5) National Ambient Air Quality Standard (NAAQS) is a top priority for the Biden Administration. Currently, a rule update is proposed for summer 2022 to be made final in spring 2023. Lowering the annual PM2.5 NAAQS from its current level of 12.0 μg/m3 could have substantial implications for facilities as they perform air dispersion modeling for construction permit applications or air permit renewals. There has been no decision to date on whether the administration will also reconsider the ozone NAAQS.

The Boiler Maximum Achievable Control Technology (MACT) remand rule could become final this fall if U.S. EPA keeps to their schedule. Questions remain around the tighter limits that were proposed for new sources and whether they will retroactively be applied to boilers built after 2011. Look for an ALL4 Boiler MACT blog when the final rule is published.

ALL4 is also working with the wood products industry as U.S. EPA is evaluating further changes to the Plywood and Composite Wood Products MACT rule. U.S. EPA’s current rulemaking schedule has them issuing an information request to select facilities in late 2021, proposing rule changes in late 2022, and finalizing a revised rule in late 2023.

We have heard from many state regulators on their thoughts and activities around Environmental Justice (EJ) and New Source Review (NSR) topics such as project aggregation and project emissions accounting (PEA). Many states are addressing EJ within certain permit reviews and are working to make public awareness and accessibility a priority even with the challenges that COVID has brought. If you have questions about what your state is doing around EJ, please reach out.

With President Biden’s executive order to review the regulations finalized by the previous administration —including the October 22, 2020 Project Emissions Accounting Final Rule—states have varying approaches on how they are implementing PEA. Facilities should be sure they understand their state’s approach before submitting any construction permit applications. There also seems to be increased focus on evaluating project aggregation when facilities have submitted more than one air permit application in a multi-year period. Reach out to ALL4 if you need help developing an air permitting strategy.


Waters of the United States (WOTUS) continues to be a hot topic. On July 30, 2021 President Biden reversed the current WOTUS rule enacted under the Trump Administration. For a deeper look at WOTUS Woes, read ALL4’s recent blog post on the topic.

On September 8, 2021 the U.S. EPA released Preliminary Effluent Guidelines Program Plan 15 (Plan 15). One of the new rulemakings under Plan 15 centers around per- and polyfluoroalkyl substances (PFAS) discharges in wastewater. A review of Pulp, Paper and Paperboard point sources were included in the Plan 15 study. As a result of the information collected and reviewed, no PFAS guidelines were recommended for the pulp and paper or timber products industry as a part of Plan 15.


Environmental Social Governance (ESG) is simply defined as a mechanism to assess non-financial metrics of a company. This is accomplished via an ESG rating. Investors are becoming more interested in a company’s commitment to having a positive impact in its community instead of solely focusing on financial indicators. However, multiple rating systems exist and incorporate data from varying sources. This means that a single company can have multiple scores and have varying ranks across the different systems.

While corporate-wide policy making and high-level financial decisions are probably outside many job descriptions, there is a real way you can affect your company’s ESG profile. The data contained in so many environmental reports (i.e., Federal Greenhouse Gas Report, Tier II, TRI Form R) is used in ESG ratings to track metrics such as energy and water usage, waste reduction efforts, and heavy metal emissions. Being cautious not to report overly conservative values is becoming more important as the data is becoming more visible to the general public.

ESG and EJ issues are at the forefront of policy making, and companies need to be aware of how this could affect their business operations moving forward. Do you have questions about ESG or EJ? Visit our Services page for more information.

We look forward to continuing to support the forest products industry and are hopeful that we will be able to have more in-person meetings in 2022. If you have any questions about any of the information presented above, please reach out to Anna Richardson at arichardson@all4inc.com or 678.293.9425.


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