Environmental Regulations and Sustainability Initiatives-Role of Science and NCASI

Transcription

1 Environmental Regulations and Sustainability Initiatives-Role of Science and NCASI Ashok K. Jain, NCASI April, 2017 ncasi

2 Outline Introduction Environmental Rule Making Process Bringing Science and Data Into the Process Current Trends in Assessing Sustainability Role of Science in Assessing Sustainability Concluding Remarks 2

3 Who We Are? >50 scientists, engineers, and associates Annual budget ~$13 million Our Members 80 US Member companies representing ~80% of paper and paperboard production ~70% of wood panel production more than half of industrial timberland acreage 20 Canadian Member companies 25 Sustaining Member companies 3

4 NCASI Locations Anacortes Montreal Corvallis Cary New Bern Newberry Headquarters Regional Centers Aquatic Biology Forestry and other staff at locations around the US 4

5 ncasi adding value through science, communication, support, education Industry-Specific Science that Positively Affects Policy, Regulations, and Acceptability Expert Analysis and Communication of Current and Emerging Issues Exceptional Member Support to Enhance Performance and Minimize Cost Employee Development and Education 5 ncasi

6 How Federal Environmental Regulations are Developed Federal Laws Dictate Regulation Development Relevant agency establish priority and schedule Agency staff collects, solicits, and analyzes the available data Rule is Proposed with Request for Comments Agency seeks comments on its methodology, data analysis, data quality and new data Agency generally is open to discussions on its methodology, data needs, costs, etc. Rule is Finalized or Reproposed, if Court Challenges are Successful Rule is finalized and published in the Federal Register with implementation dates. Limited staff resources are available for implementation guidance but it disappears quickly 6

7 Agency Limitations in Promulgating Regulations Limitations on Time Limitations on Resources Knowledge Gap Statutes specify time Court ordered deadlines Agency budgets are limited Almost no resources are provided for new studies or method development to assess ability to comply No in-house capability to conduct studies to implement regulations Often staff from different groups are brought in to write a regulation. It is unlikely to have expertise at an agency in every regulated industry.

8 NCASI s Advantages in Addressing the Science Aspects of Industry-Specific Regulations Limitations on Time Limitations on Resources Knowledge Gap We understand the time constraints You can have the best information but it has to be available in time to be of benefit Industry provides needed resources In-house capability to conduct studies Staff understands the industry and its processes NCASI has access to industry experts

9 2011 Boiler MACT Rule and Costs for Forest Products Industry Issue Broader Impact Estimated Costs ($) Dioxin / Furan Work practices Inability to operate No proven technologies to achieve Dec 2011 limits. Cost estimated at: PM limits and use of PM CEMS Mercury (Hg) Inability to certify compliance with CEMS Inability to demonstrate compliance >$1 billion >$ 1 billion >$100 million CO Expensive retrofits >$500 million >$ 2.6 billion 9

10 2011 Boiler MACT Rule Changes and Savings based on NCASI Technical Comments Issue Key Changes Estimated Savings ($) Dioxin / Furan Work practices PM limits and use of PM CEMS Mercury (Hg) CO Work practice in place of numerical limits No CEMS monitor requirement for all boilers No CPMS for biomass Limit at method quantitation/reporting level Higher limits for boilers with and without monitoring systems $1 billion $ 1 billion $100 million $500 million $ 2.6 billion 10

11 EPA s Need for a Method for an Acceptable Method for Measuring VOC Emissions from Wood Products Sources Issue Facilities received NOVs for not measuring VOC emissions using Method 18 Method 25A results unacceptable to EPA Method 18 not practical when mixture of VOCs is unknown NCASI Research Extensive tests to characterize emissions to identify major classes of compounds Proposed a modification to method 25A to overcome its limitations Resolution EPA and states have approved the use of this method Facilities are able to conduct tests with significant cost savings

12 Develop Effluent Guidelines for Pulp and Paper Industry Issue EPA routinely reviews the effluent guideline standards to decide if new technologybased standards are needed Preliminary analysis suggested that pulp&paper was a leading candidate on the basis of TRI data NCASI Research Staff worked with member companies to examine the TRI data and determined that the TRI data were based on using ½ detection limits for non-detected compound as per EPA guidance Resolution EPA concluded that new standards were not needed EPA s detailed study referenced NCASI science times in its report

13 Sustainability: The new Challenge Government Driven Customer/NGO Driven and Science Based Perception/ Environmental Activist Driven Greenhouse Gases Biogenic Carbon The Sustainability Consortium Sustainability Accounting Standards Board (SASB) WBCSD Environmental Product Declarations (EPDs) Product Category Rules Water Footprint Natural Capital Energy/Water Nexus Certification Standards Product Stewardship Zero Waste Benchmarking Etc.

14 NCASI s Sustainable Manufacturing Program Shifting our frame of reference to that of the customer and general public to design and undertake research based in science that delivers final products focused on addressing regulatory development and our members communication needs

15 Tools and Analyses: GHG Calculation Tools Guidance Documents & Excel Workbooks

16 Direct Contributions to Regulation and Standard Development Review and provide comments on proposed environmental regulations related to climate change In Canada In U.S. (e.g., biogenic CO 2, Clean Power Plan? ) Participate (directly or by providing comments) in standard development where appropriate e.g.: WRI/WBCSD GHG Protocol Western Climate Initiative ISO Etc.

17 Direct Stakeholder Education Contribution to reports by internationally-recognized organizations e.g., Complementarity of Fresh & Recycled Fiber (WBCSD) Global Industry Carbon Profile (FAO) LCA & Biodiversity (IEA) Peer-reviewed publications, e.g., Greenhouse gas and carbon profile of the U.S. forest products industry value chain Carbon benefits of using manufacturing residues for energy Biodiversity considerations in LCA of biomass harvesting Presentations in various forums

18 Summary One Regulatory agencies are assigned the difficult task of writing regulations without adequate funds or time and do not always have in-house expertise Two Sound scientific data and technical engagement affect regulatory outcomes and play an important role in the area of sustainability Three Sustainability is a multifaceted new challenge that industry must meet because it is often driven by customers and activists who can influence customer decisions

19 ncasi adding value through science, communication, support, education Industry-Specific Science that Positively Affects Policy, Regulations, and Acceptability Expert Analysis and Communication of Current and Emerging Issues Exceptional Member Support to Enhance Performance and Minimize Cost Employee Development and Education 19 ncasi

20 Questions? Ashok Jain ( )