Comments from American Forest and Paper Submitted to EPA Regarding the Advanced Notice of Proposed Rulemaking for Greenhouse Gases Under the Clean Air Act

The American Forest & Paper Association (“AF&PA”) appreciates the opportunity to submit comments on the Advanced Notice of Proposed Rulemaking: Regulating Greenhouse Gas Emissions Under the Clean Air Act (“ANPR”). 73 Fed Reg. 44354 (July 30, 2008). AF&PA is the national trade association of the forest, pulp, paper, paperboard, and wood products industry. The U.S. forest products industry accounts for approximately 6 percent of the total U.S. manufacturing, placing it roughly on par with the automotive and plastics industries. The forest products industry generates over $200 billion a year in sales and employs more than one million people earning $54 billion in annual payroll. The industry is among the top ten manufacturing sector employers in 48 states. We support policy efforts to increase our nation’s energy security, and our member companies are leading the effort to achieve this objective by combining advanced technology and innovative manufacturing practices with responsible stewardship of our nation’s natural resources.