Page 101

The Ecology of Industry, 1998. Pp. 101-141
Washington, DC:  National Academy Press

The Pulp and Paper Industry

A. DOUGLAS ARMSTRONG, KEITH M. BENTLEY, 
SERGIO F. GALEANO, ROBERT J. OLSZEWSKI, 
GAIL A. SMITH, AND JONATHAN R. SMITH JR.

Introduction

Like other industries, the pulp and paper industry (referred to in the rest of this paper as ''the industry") has come under increasing scrutiny for its potential environmental impacts. More than many other industries, however, this industry plays an important role in sustainable development because its chief raw material—wood fiber—is renewable. The industry provides an example of how a resource can be managed to provide a sustained supply to meet society's current and future needs.

This paper looks at the U.S. industry's current experience and practices in terms of environmental stewardship, regulatory and nonregulatory forces, life cycles of its processes and products, and corporate culture and organization. It describes near-term expectations in these areas and examines opportunities for overcoming barriers to improvement. It also provides an industry perspective on the most significant environmental issues of historical and future importance. Although the emphasis here is on complexity, shortcomings, and barriers, the industry has, in fact, continually improved its environmental performance while increasing its business. The problem areas are given more emphasis to highlight some of the challenges to be addressed.

Environmental Stewardship

Wood is the chief raw material of the pulp and paper industry. In 1991, the worldwide harvest of roundwood for lumber and wood-panel products as well as pulp and paper was 1,599,272,000 cubic meters (Canadian Forest Service, 1993),



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Page 101 The Ecology of Industry, 1998. Pp. 101-141 Washington, DC:  National Academy Press The Pulp and Paper Industry A. DOUGLAS ARMSTRONG, KEITH M. BENTLEY,  SERGIO F. GALEANO, ROBERT J. OLSZEWSKI,  GAIL A. SMITH, AND JONATHAN R. SMITH JR. Introduction Like other industries, the pulp and paper industry (referred to in the rest of this paper as ''the industry") has come under increasing scrutiny for its potential environmental impacts. More than many other industries, however, this industry plays an important role in sustainable development because its chief raw material—wood fiber—is renewable. The industry provides an example of how a resource can be managed to provide a sustained supply to meet society's current and future needs. This paper looks at the U.S. industry's current experience and practices in terms of environmental stewardship, regulatory and nonregulatory forces, life cycles of its processes and products, and corporate culture and organization. It describes near-term expectations in these areas and examines opportunities for overcoming barriers to improvement. It also provides an industry perspective on the most significant environmental issues of historical and future importance. Although the emphasis here is on complexity, shortcomings, and barriers, the industry has, in fact, continually improved its environmental performance while increasing its business. The problem areas are given more emphasis to highlight some of the challenges to be addressed. Environmental Stewardship Wood is the chief raw material of the pulp and paper industry. In 1991, the worldwide harvest of roundwood for lumber and wood-panel products as well as pulp and paper was 1,599,272,000 cubic meters (Canadian Forest Service, 1993),

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Page 102 or roughly 960 million metric tons. Approximately 63 percent of that wood, or 605 million metric tons, was used to manufacture 243 million metric tons of pulp, paper, and paperboard. The U.S. share of that production was 71 million metric tons, or 29 percent of the total, according to the 1994 Lockwood-Post's Directory of the Paper and Allied Trades (Miller Freeman, 1994). The industry in the United States employs over 690,000 people. The availability and affordability of forest products and the economic health of the industry have always depended on the sustainable use of the forest resource. Significant management and technological improvements, such as plantation forestry and the development of the chemical-recovery cycle, were made a half-century ago. These improvements and improvements made since then have contributed to the sustainability of the industry and to the health of the environment. The industry believes that its current industrial operations affect the environment minimally, due to the many improvements the industry has made to its environmental practices. However, as consumer and government concern about environmental impacts grows, the industry's environmental performance will be increasingly scrutinized. This scrutiny and the industry's commitment to improving its practices on the basis of good science and sound economics suggest possible changes in environmental practices on several fronts. Silviculture: Managed Forestry Intensive forestry, or silviculture, involves the efficient production of wood resources and has features in common with agriculture. Forestry, however, uses land far less intensively than agriculture, because the growth rotation cycles of trees require years, not months. Also, unlike most agricultural harvests, typically only a fraction of the growing forest is harvested in any given year. On a 15-year-average rotation, for example, one-fifteenth of the acreage on a tree plantation will be clear-cut in a given year. Thus, the majority of the land involved remains undisturbed, save for occasional clearing of understory to reduce competition for nutrients. Reforestation, the replanting of harvested acreage (or acreage lost to fire or flood), is another practice of intensive forestry. It ensures that the average rate of wood growth, expressed as the increase in the volume of wood per year per acre, is higher than it would be if the woodland were not harvested at all or were left to regenerate naturally. As in agriculture, silvicultural practices include genetic improvement, regeneration, scientific management, appropriate scheduling of harvests, fertilization, and control of competing vegetation, insects, and disease. These practices help minimize the acreage needed to harvest a unit of wood. Silviculture, like agriculture, also must take into consideration the non-point-source pollution that could arise as a result of erosion and chemical applications such as fertilizing. Because

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Page 103 silviculture is less intensive than agriculture, the risk of environmental damage is less than it is in the case of agriculture. Reforestation results in more trees being planted, by a wide margin, than are harvested. There might be as many as six times more trees planted than harvested, depending on who owns the land (the ratio is higher on lands owned and managed by forest product companies) and whether or not the industry is at a higher or lower productivity level. Reforestation not only contributes to forest cultivation but also compensates for trees lost to fire, insect damage, and floods. Under current regulations, many smaller landowners in the United States might opt not to replant at all or might convert the land to agricultural or other use. In addition to the measures outlined above, other improvements are being made on commercial forest lands, as appropriate. These include practices to enhance protection of various biotic species, wetlands, and water quality. In general, the basic practices of intensive forest management represent significant advancement in sustainable use of wood resources. Sustainable development, based on good science, is a goal that now guides the industry's practice. The principles of sustainable forestry (Box 1) adopted by members of the American Forest and Paper Association (AFPA) show the industry's commitment to the environment (American Forest and Paper Association, 1995). Today, the industry in the United States gets the bulk of its raw material from nonindustrial private landowners. Intensity of harvesting varies significantly on these sites and depends on the objectives of the individual landowners. Private landowners get professional advice from a variety of sources, such as state forestry organizations, consultant foresters, and industrial landowner assistance programs. Some forest products companies provide support to their suppliers through management assistance programs (MAPs). At a minimum, these programs provide training desired by environmentally conscious landowners. At the buyer's discretion, compliance with the sustainable forestry management principles can be a criterion for continuing the business relationship. The industry faces several forestry operation challenges. These include the harvesting methods used, the protection of threatened and endangered species, and potential restrictions on wood harvesting. Harvesting Methods There are two ways to determine length of the harvest cycle of trees: end use of wood or ecosystem impact. End use is the more direct method of determining the harvest cycle; dimensional lumber requires older trees than does pulpwood, for example. The effect of ecosystem considerations on the harvest cycle are more complex and might be driven by factors such as determining the proportion of older growth needed to protect a species habitat. Forest renewability includes practices such as clear-cutting that are perceived to be environmentally destructive. Depending on the degree and timing of commercial and environmental

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Page 104 BOX 1   Principles of Sustainable Forestry ·      Broaden the practice of sustainable forestry by employing an array of scientifically, environmentally , and economically sound practices in the growth, harvest, and use of forests. ·      Promptly reforest harvested areas to unsure long-term forest productivity and conservation of forest resources. ·      Protect the water quality in streams, lakes, and other bodies of water by establishing riparian protection measures based on soil type, terrain, vegetation, and other applicable factors, and by using EPA-approved Best Management Practices in all forest management operations. ·      Enhance the quality of wildlife habitat by developing and implementing measures that promote habitat diversity and the conservation of plant and animal populations found in forest communities. ·      Minimize the visual impact by designing harvests to blend into the terrain, by restricting clear-cut size, or by using harvest methods, age classes, and judicious placement of harvest units to promote diversity in forest cover. ·      Manage company lands of ecological, geological, or historical significance in a manner that accounts for their special qualities. ·      Contribute to biodiversity by enchancing landscape diversity and providing an array of habitats. ·      Continue the prudent use of forest chemicals to improve forest health and growth while protecting employees, neighbors, the public, and sensitive areas, including stream courses and adjacent lands. ·      Broaden the practice of sustainable forestry by further involving nonindustrial landowners, loggers, consulting foresters, and company employees who are active in wood procurement and landowner assistance programs. ·      Publicly report progress in fulfilling commitment to sustainable forestry. ·      Provide opportunities for the public and the forestry community to participate in the commitment to sustainable forestry. needs, many other, lower-intensity treatments such as periodic thinning or selective harvesting can be applied to industrial commercial forest lands. However, most North American commercial forests eventually need good sunlight to reproduce successfully, and clear-cutting is used to accomplish this goal. Moreover, plantation forests are usually more economically planted, managed, and harvested. Decisions on what harvesting techniques to use depend on the landowner's objectives, characteristics of the site, and forest conditions.

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Page 105 Protection of Threatened and Endangered Species The forest products industry on its own and in collaboration with governments is intensifying efforts to protect threatened and endangered species. Companies are helping to identify the presence of such species on managed lands and are incorporating specific habitat management schemes into existing stand management and harvesting programs. The species-by-species approach, inherent in efforts to protect threatened and endangered species, does not take into account the impact of intensive forestry on entire ecosystems and the many species living in them. However, in the absence of better understanding of the effect of harvesting and reforestation on ecosystems, it is the approach being used. Potential Restrictions on Wood Harvesting Loss of biodiversity, potential global warming, and deforestation are increasing pressure to retire woodlands, particularly forested wetlands and old-growth forests, from production and to restrict the harvesting of wood from public lands. Yet, abandoning the productive use of forests might not be the best course to address these concerns. For example, existing forestry practices have been shown to increase landscape diversity and carbon sequestration beyond that achievable in the absence of human activity. Plantation forestry supports habitats for endangered species. At a minimum, the objective is to maintain, not necessarily expand, such populations on forest lands. Trade-offs will be necessary in making these environmental decisions. Turning Wood into Paper Paper can be made from virtually any fibrous material, including cotton, sugar cane, and bamboo, but the vast majority is made from trees. The species and variety of trees used are important determinants of the type of paper produced. Some trees, such as pine, yield long fibers that are strong and absorbent (good for paper towels, for example), whereas others, such as hardwoods, are shorter and form a smoother surface (good for printing purposes). In the tree, wood fibers are bound together by an organic polymer called lignin. To make paper, individual wood fibers must be separated from each other (defiberized) in one of a variety of pulping processes. The separation can be achieved mechanically by grinding the lignin (groundwood process) or chemically by dissolving it. In chemi-mechanical or semichemical pulping, a combination of the two processes is employed. Groundwood pulps, such as newsprint, are less costly to make but are of lesser quality in terms of strength and brightness. Chemical pulping processes, which are described more fully below, remove more lignin and yield essentially individual wood fibers, which can be converted into many products, from liner-

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Page 106 board (the walls of corrugated boxes) to tissue paper or magazine stock. After pulping, chemical pulps are washed to remove and recycle the chemicals used and might be bleached white in a variety of bleaching sequences depending on the desired end product. Finally, the pulp is dried on one of several types of paper machines or pulp dryers. In such machines, most of the water in the pulp is first squeezed out by passing the wet pulp web through a press. Coatings or dyes might be added to the web. Then, the pulp is dried to less than 10-percent moisture by heated steel rolls or hot air. At the end of the machine, the dried pulp might be baled and sold as market pulp for converting to final products in other facilities, or it might be converted directly into paper or paperboard, depending on the thickness and weight of the sheet, by passing it between high-pressure rollers called calenders. The Pulping Process The following discussion centers on chemical pulping processes (Casey, 1983; Saltman, 1983), which supply more than two-thirds of the world's wood pulp. Chemical-recovery processes are used routinely in most chemical-pulping processes. First used a half-century ago, these processes now result in the recovery of 90 percent of the inorganics, which are reused as described more fully below. Nearly 100 percent of the dissolved organics are converted to energy. The most widely used chemical pulping process in paper making is the sulfate, or kraft, process. It was invented in 1889. In the 1930s, the process was enhanced with chemical recovery. Other chemical-pulping processes (mainly using acid sulfite and soda) are sometimes combined with various chemical-recovery subprocesses. The typical kraft process involves turning logs into wood chips (Figure 1), which are then pulped (Figure 2). The wood chips are pulped under high heat and pressure in continuous- or batch-digestion processes using white liquor (a water-based solution of sodium hydroxide and sodium sulfide). The white liquor dissolves the lignin and frees the cellulose fibers. Some of the cellulose is hydrolyzed to methanol, acetone, and other volatile and water-soluble organics. Some of the cellulose reacts with the sulfide ion to produce sulfonated organics, such as methanethiol, which can cause odor problems. When digestion is complete, the digester contains a mixture of brown stock (wood fiber) and black liquor. Black liquor is a mixture of sodium compounds (sodium hydroxide, sodium sulfide, sodium sulfate, and sodium carbonate), organic compounds, and salts including lignins and resins. Turpentine (a mixture of branched aromatic hydrocarbons) is also released from the wood in varying quantities, depending on the wood species. Substances that are gaseous at digester pressure and temperature, including some methanol, acetone, organosulfurs, and most of the turpentine, are vented during digestion to condensers, where the turpentine is recovered for sale. Typically, nearly 100 percent of the noncondensible gases, which contain the odor

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Page 107 FIGURE 1 Wood-handling process.

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Page 108 FIGURE 2 Pulping process.

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Page 109 compounds, methanol, and acetone are collected and destroyed by incineration in other combustion units in the mill. The sulfur dioxide from oxidation of the organosulfurs is generally scrubbed with alkaline liquors. After digestion, the black liquor is separated from the brown stock pulp, usually by countercurrent drum washing. The brown stock might be screened and refined mechanically either before or after washing. Some methanol, acetone, and odor compounds might be volatilized and released during washing. Depending on regulatory requirements and aesthetic considerations, some mills capture and incinerate the gases that are released. The brown stock from the washing process is further delignified by bleaching, or sent to a paper machine. About 1.5 percent of the original weight of wood is dissolved organic material lost to waste treatment, and another 1 to 3 percent is fine fiber lost in primary and secondary wastewater treatment facilities. Typically, 90 percent of these losses are removed from the effluent prior to discharge to the environment. The resulting fiber fines and waste-treatment sludge—both of which are nontoxic and nonhazardous solid waste—constitute the majority of the solid waste generated by a pulp mill. The black liquor, now containing about 7 percent inorganic salts and about 7 percent soluble organic material, is routed to evaporator systems, which increase the total solids to 50 to 75 percent to sustain combustion. During evaporation, additional methanol and odor compounds are evolved from the liquor. The vapor fraction is incinerated in the same combustor used to incinerate the digester noncondensibles. Before the mid-1970s, direct-contact evaporators (DCEs) were retrofitted on recovery furnaces to recover particulate matter from the hot flue gases, which, in turn, concentrated the solids to about 65 percent before firing. Later, black-liquor oxidation systems were installed to convert the sulfide content in the black liquor to stable materials to meet the total reduced-sulfur (TRS) emission regulations. However, newer low-odor furnace systems use additional evaporator units called concentrators instead of the DCEs. The net effect has been the removal of about 20 percent of mill odor emissions at an additional capital cost of several million dollars. Evaporator condensates are generally recycled for use as wash water for the pulp. To maximize water reuse, the more odorous of these condensates are often steam stripped and incinerated. During the evaporation of black liquor from softwood pulping, tall oil soap (a mixture of sodium resinates named after the Swedish word for pine) floats to the surface of the liquor. It might be skimmed off and acidulated to the oil form. Rather than burn the soap along with the rest of the organic materials in the black liquor, it is sold to refiners for use in a variety of products from paper additives to cosmetics. Acidulation of soap liberates hydrogen sulfide, which is often collected by mills and scrubbed or incinerated. The concentrated, or heavy black, liquor is fired in a specially designed chemical-recovery furnace, where the organic portion is combusted to produce steam and subsequently electrical energy by cogeneration. The inorganic portion, now separated from the organic portion, is recovered and converted back into the

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Page 110 chemicals used for pulping. It forms a molten smelt in the bottom of the furnace, where sulfate is reduced to sulfide. This smelt runs off into dissolving tanks and results in green liquor—an aqueous solution of principally sodium sulfide and sodium carbonate. The boiler gases contain carbon dioxide, carbon monoxide, oxides of nitrogen, sulfur dioxide, traces of hydrogen sulfide, and sodium sulfate particulate. In most instances, a high-efficiency electrostatic precipitator is used to remove the particulate matter, which is redissolved in the incoming black liquor. Emissions of reduced sulfur compounds, carbon monoxide, oxides of nitrogen, and sulfur dioxide are controlled by proper furnace design and management of fuel and air. Hydrogen sulfide, or TRS, emissions are regulated by operational permit and are generally low enough to avoid causing ambient odor. Dissolving the smelt liberates some hydrogen sulfide and particulate matter, which are controlled by alkaline scrubbers mounted on the dissolving-tank vents. A few mills also trap the odors given off by black-liquor storage tanks and incinerate them. The green liquor from the dissolving tanks goes to a recausticizing system, so named because calcium oxide is added to it to convert the sodium carbonate to caustic soda. The green liquor is thus converted into white liquor, thereby completing the main chemical-recovery cycle. Inorganic impurities in the liquor cycle, such as silica and iron, are separated as dregs and grits. The dregs and grits are disposed of as solid waste, although some uses for them as inert filler have been found. Another recovery cycle is employed to recycle the calcium used for recausticizing. The calcium carbonate formed in the causticizers is removed by gravity in white-liquor clarifiers or by filtration and washed to remove sodium salts. The weak-wash water, still highly alkaline, is generally recycled to the smelt dissolving tanks. The calcium carbonate "mud" is then thickened and introduced into a specially designed kiln, where it is calcined back to calcium oxide using an oil or gas flame. Bag filters are often used to control particulates arising from the handling of dry lime. The lime kiln produces emissions that must be controlled. Particulates are removed by either a high-efficiency scrubber or an electrostatic precipitator. Traces of sulfide in the mud liberate hydrogen sulfide by carbon-dioxide stripping, so hydrogen-sulfide emissions are controlled by effective mud washing, scrubbing, and sometimes by oxidation. In addition to the main chemical-recovery furnace, most kraft pulp mills burn wood waste associated with the pulping process in boilers. This waste is in the form of bark from pulp logs and chip fines and oversize material removed in the screening of wood chips that cannot be reused. Primary clarifier sludge might also be disposed of by burning. If the total steam produced from the recovered black-liquor solids in the chemical-recovery boiler and the normal quantity of wood waste in the wood-waste boiler are insufficient for the needs of the mill, additional wood waste might be purchased. The deficit might also be made up

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Page 111 with fossil fuels such as coal, gas, or oil. Older kraft mills that use fossil fuels for energy might use a third boiler. These older mills generally have to use some fossil fuels because the older processes are less efficient. Newer kraft pulp mills derive almost all necessary steam and electrical energy from renewable resources such as black liquor and wood waste, and therefore require the use of very little, if any, fossil fuels. This, however, does not apply to lime kilns, which are generally fired with gas or oil. Bleaching of Pulp The further delignification, or bleaching, of pulp produces additional air and water discharges. Bleaching involves adding chemicals to wet pulp to remove more lignin (color). There is considerable variation in bleaching processes. Until recently, the preferred sequence to produce high-brightness pulps was the application of chlorine gas or chlorine water (''C" stage), followed by aqueous caustic soda and/or sodium hypochlorite extraction ("E/H"), followed by aqueous chlorine dioxide application ("D"), followed by another E stage and another D stage. The effluents from the alkaline E stages contain organic material equivalent to 1 to 3 percent of the total pulp weight as the result of delignification and some breakdown of cellulose. The effluent from the latter E stage is generally reused at least once for pulp dilution and washing in a "jump-stage" manner from E to E/H. The acid effluents from the D stages are reused in preceding acid stages in a similar jump-stage manner. Thereafter, they are generally handled separately to avoid evolution of hydrogen sulfide in the other mill effluents. In recent years, concern has arisen over the formation of chlorinated organic compounds, including dioxin, during chlorine bleaching. The industry responded to the public perception of possible harm, choosing to take remedial actions even before major questions about the toxicity of these compounds were answered. Almost all mills now have taken steps to reduce the formation of dioxin and other chlorinated organics. Typical methods include reducing hypochlorite use, which reduces emission of chloroform, and substituting chlorine dioxide for chlorine in the C stage of bleaching, which reduces the formation of dioxin and other polychlorinated organics. Solids dissolved in bleach-plant effluents have historically been pumped to external treatment prior to being discharged into the environment. Their recovery and reuse through the liquor chemical-recovery cycles have been rare because added evaporation requirements and the presence of chlorides, which are corrosive above certain concentrations in the process liquors, can lead to explosions in the smelt dissolving tanks. Chlorine dioxide, substituted for chlorine to reduce the formation of chlorinated organic compounds, is an unstable compound and must be generated at the point of use. Proprietary methods for doing this involve the acidification of sodium chlorate in the presence of a reducing agent and sometimes a catalyst. The

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Page 131 EPA's voluntary Energy Star program is designed to reduce emissions of ''criteria" and greenhouse gases through increased energy efficiency. It includes Green Lights (focusing on lighting efficiency), Energy Star Computers (focusing on computer and office-system energy efficiency), and Energy Star Buildings (focusing on heating and air conditioning efficiency). These initiatives are directed more at office, warehouse, and light-industrial situations, but forest products companies are looking at the technologies being promoted even if they are not directly participating in the program. One of the latest EPA voluntary initiatives is the Environmental Leadership Program, which recognizes companies that have perfect environmental records. The Energy Policy Act of 1992 created a voluntary program of reporting of carbon dioxide emissions that is intended to quantify national output of greenhouse gases. In the past, reporting has often been the forerunner of regulation. How this turns out depends largely on the evolution of the science surrounding the greenhouse effect and the international response to the Climate Change Convention of the Earth Summit of 1992. Government and industry are cooperating increasingly at the highest levels. The best example of this is the President's Council for Sustainable Development, which includes a representative of the forest products industry. The council's activities have not progressed far enough at this writing for their effect on U.S. policy and performance to be assessed. Voluntary programs are an underutilized means of improving environmental conditions. There is a misconception that voluntary programs do not work because they have no teeth, or that they will not be supported because no one will voluntarily place their company at an economic disadvantage. This way of thinking ignores the fact that corporations are being increasingly open about their environmental practices and are now accountable to the public as well as to regulatory officials. It also flies in the face of the fact that economic benefits can result from good environmental stewardship. Some barriers to successful voluntary programs are mentioned in the last section of this paper. The Role of Public Opinion and Customer Demands Less quantifiable but as important as government mandates and industry's voluntary efforts are public opinion and customer demands, whether the result of media coverage or pressure from environmental organizations. Perhaps the most significant of these is news media coverage of environmental news, which has grown dramatically since the first Earth Day in 1970. This coverage has been driven in large part by high-profile environmental disasters such as Three Mile Island, Bhopal, Times Beach, Love Canal, and the Exxon Valdez. The increased media interest in the environment has generated greater interest from the public, and as a result, the pulp and paper industry is being held to ever higher environmental standards. The industry operates in a society that de-

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Page 132 mands that it protect the environment. If it does not, society is going to make it increasingly difficult for the industry to continue to operate. Because of this realization, pulp and paper companies are taking steps to ensure that they are environmentally responsible and that they clearly communicate their records, progress, and plans. Since 1992, industry management, acting through the industry's association, has adopted a set of environmental, health, and safety principles (American Forest and Paper Association, 1992) and a set of sustainable forestry principles (American Forest and Paper Association, 1995). These principles are a public declaration and commitment by the industry to serve consumer needs for forest products while protecting environmental quality and sustainably managing the forest for present and future generations. AFPA member companies have promised to promote successful reforestation of nonindustrial private land through cooperative efforts with landowners, federal and state agencies, and other elements of the forestry community. AFPA members will use responsible practices in their own forests and will promote sustainable forestry practices among other forest landowners. Landowners selling timber to AFPA members will be asked to make informed decisions about reforestation. Many companies in the industry have gone even further to demonstrate environmental stewardship. They have established company-specific principles and codes of environmental conduct and set up departments exclusively focused on ensuring environmental compliance and improving environmental performance beyond regulatory requirements. A number of firms have established a regime of internal facility audits and publish environmental reports covering issues such as emissions data, environmental capital expenditures, and environmental problem areas. On the resource side, many pulp and paper companies have voluntarily changed their management practices to provide more multiple-use values, such as wildlife habitat and recreational opportunities. In cases where forest land is home to an endangered or threatened species, many industrial landowners have taken the initiative to establish species-protection programs that are also compatible with commercial timber management. Customer demand is another factor that has changed the way the industry operates. At the vanguard are customer demands for more products with recycled content. The pulp and paper industry also has responded to demands for reduced packaging, and in the United States, customer demand is developing for ECF (elemental chlorine free), TCF, and even unbleached papers. The ISO has also accepted a mandate to promote changes in corporate culture aimed at benefiting the environment. For example, the ISO Environmental Management Standards subcommittee is developing certain minimum corporate environmental management, training, and communication structures. Companies will need to document their adherence to these to secure ISO certification in the future. AFPA and individual companies are providing input to the development of these standards. Standards for environmental performance will only get more stringent.

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Page 133 In many ways, the easy choices have already been made. In spite of the pulp and paper industry's consistent performance improvements, in the future it will no longer be business as usual. Near-term issues such as air and water quality, recovery and recycling, and forest practices and timber supply already are giving way to worldwide issues such as global warming, depletion of the ozone layer, and sustainable development. The question the public, the regulators, and the environmental organizations will ask is not, Can the pulp and paper industry create a mill with no emissions? but How soon can they do it? The pressure to accomplish this will be intense. In addition, the industry will be challenged to make even more efficient use of the forest resource, to develop alternative products, and to recover and reuse ever-increasing amounts of its products. Initiatives by many companies to report environmental information to the public invite public feedback. For this and other reasons, the public will become more and more interested in industrial processes and their effects on the environment and the local community. Also, the public will increasingly have a say about what pulp and paper manufacturers can and cannot do in operating their facilities. It is important for the industry to meet formally with regulators on a regular basis, perhaps every 2 years, to discuss current environmental problems and how to resolve them. The collaborative efforts between EPA and industry in developing the New Source Performance Standards regulations 20 or so years ago provide a good example. A glossary of environmental terms should be developed as part of this process and agreed upon by regulators, industry, and other stakeholders. For example, "minimum environmental impact" should be defined in terms of adverse effects. It is also important for industry and regulators to work closely together to transfer the technical knowledge needed to develop adequate regulations. Shaping a Positive Future The industry has many opportunities to shape a positive future. First, though, the industry needs to make sure its own house is in order—that pulp and paper manufacturers truly are operating in an environmentally responsible way. Companies can improve environmental performance and waste fewer resources through better coordination of their efforts. An example is exporting wastepaper to developing nations so these countries can use their financial resources for things other than building new pulping facilities. Importation of post-consumer recycle material for use in producing paper for packaging, tissue, printing, and so forth might be an effective way to improve the ecological performance of the industry. This would be especially feasible for developing nations with low-cost sources of power. Implementing more effective environmental management systems can increase environmental awareness among all employees and help ensure company-wide application of environmental principles and policies. It can also ensure that

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Page 134 meaningful parameters of performance are communicated to company managers so that corrective action can be taken in a timely manner. In other words, what gets measured gets done. Too often, the diversity of the forest products industry has led it to follow the lowest-common-denominator strategy: setting goals so that the poorest environmental performers are able to meet them. The industry must set goals that mean something. In addition, the industry needs to get out in front of the issues and help set policy. The only way to do that is to form strategic partnerships with environmental regulators and environmental organizations to develop collaborative approaches to new environmental requirements. Given the complexity of the environmental issues ahead, the economic consequences of more environmental regulations, and the highly competitive global marketplace, pulp and paper producers do not have the luxury of letting environmental agencies go forward with unilateral command-and-control regulations. To a large degree, public perception is formed on the basis of aesthetic considerations such as visual effects. Public perception, not necessarily facts, plays a big role in the level of support the industry receives when questions about environmental performance are raised. Aesthetic design concepts used properly in such areas as scrubber plumes, noise abatement, and perimeter fencing would improve the public's impression of what is going on behind company gates. If the pulp and paper industry is to continue to make meaningful environmental progress, all the players need to be at the table to help establish reasonable environmental goals based on sound scientific principles and to identify more efficient mechanisms to meet those goals. This will not be an easy process. There are strong opinions and plenty of suspicion about motives on all sides. To carry out what the public demands—protection of the environment—and provide what the public needs—a strong economy—the industry must work collaboratively. This spirit of cooperation is one the whole industry has to embrace. No one company can do it alone. Clearly, environmental issues do not respect state, national, or international boundaries. Environmental policies and decisions made in one country or region can affect the environmental debate worldwide. By working together to develop innovative policies and programs, the pulp and paper industry has an opportunity to replace confrontation with cooperation, promote economic growth, and improve environmental quality. Improving Industry Environmental Practices Setting Environmental Objectives There is no accepted protocol in the United States for setting long-term environmental objectives. One reason for this, perhaps, is that the history of the command-and-control structure of environmental regulations in this country dis-

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Page 135 FIGURE 4  Matrix of possible human health objectives. courages cooperative agency-industry development of environmental goals. This is a major barrier to progress. The first step is to decide what overall objectives the country should be striving for. For each major environmental issue, such as human health effects, an objective should be picked using a scientifically based public consensus process. Figure 4 illustrates the range of possible objectives. Once made, the selection should be adhered to. Oftentimes, Congress and the federal agencies seem to decide what is important based on current media and public attention or political payoff. These forces typically exert an effect for a relatively short period, typically about 3 years. This is much less time than it takes for environmental problems to respond to corrective action, often 15 to 20 years. What happens can be compared to an automobile cruise control. Like environmental rules, a cruise control is intended to establish, and minimize deviation from, a desired performance. If the throttle (Congress) reacts too quickly to changes in speed (environmental results), then speed varies wildly, the objective of reduced deviation is not met, and fuel is wasted. The short time horizon for "throttle" adjustments also causes problems related to the capital-intensive nature of the industry (indeed, of any heavy industry). First, the industry cannot afford to change manufacturing processes to incorporate new technology every few years. Modernization of facilities tends to reduce the amount of pollutants generated and released. A regulatory time scale that allows time for modernization can benefit the business as well as the environment, because modernized facilities will also be more efficient, produce higher-quality products, and be more profitable. Second, the capital-intensive nature of the industry does not allow for sufficient funds to advance the research and development of environmental technology. Therefore, industry should supplement its own research effort by collaborating with federal research initiatives.

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Page 136 The next step in setting goals is to decide which environmental problems are worth tackling, keeping in mind the objective agreed to earlier. There is tremendous variation today in the benefit society receives per environmental dollar, depending on where it is spent. This has long been recognized in industry and is now being discussed within U.S. agencies. Congress and the regulators seem too slow in appreciating that the resources for dealing with any issue are limited and that priorities must be set for environmental efforts according to environmental damage avoided per unit cost. For example, as measurement capabilities continue to improve, it might become counterproductive from an environmental standpoint to reduce releases below the point of adequate protection. That is, the mere presence of a measurable amount of a substance should not warrant regulatory control. A scientific consensus process should be developed to place environmental issues on a priority list as they arise. The ability to address items on the list must match available money. Many problems would be eliminated if objectives and goals were set through a public process. For example: ·      There would be greater agreement among all interested parties that the costs of environmental management were worthwhile; hence, there would be a higher level of compliance and fewer legal and administrative costs. ·      There would be less-frequent shifting of emphasis among environmental areas and less change within bodies of regulations. The benefits of this would include less external oversight of and better capital planning within companies. Resources that have been used to keep track of regulatory change could be diverted into economically and environmentally beneficial activities. Also, there might be fewer lawsuits. ·      Regulators could devote more of their resources to improving regulatory efficiency by streamlining existing regulations and by analyzing and understanding the connectedness of regulations. Enhancing Public Understanding of Environmental Science Better public appreciation for the impracticality—often impossibility—of achieving zero emissions or completely eliminating potentially harmful substances is needed. Careless dissemination of environmental information can lead to problems in a society in which response to environmental needs is developed democratically. Here is a partial list of steps that can be taken to improve the public's understanding of environmental science: ·      Every new law or regulation mandating greater public access to information (e.g., toxic-release inventories) should provide for public education. If lawmakers are going to require companies to publish technical information, they must provide the public with the tools to understand it

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Page 137 and not leave the task to companies ill equipped to handle it. The public (including the legislators themselves) needs and deserves to understand this information and the issues. Public misunderstanding leads to bad environmental law. Environmental rules exist, after all, to provide greater security, not to cause panic. The movement in the United States toward using risk-assessment techniques to help set priorities for environmental action could be a vehicle to correcting misconceptions of the past. ·      By being open and candid, companies can increase their own credibility, that of their industry, and that of the private sector as a whole. If industry takes this stance, any concerns it brings to the public debate are more apt to be heard and heeded. ·      The media must learn or be made aware of the stakes involved in environmental issues. Sensationalism on this topic can result in the waste of considerable resources. ·      A process needs to be developed that involves all stakeholders in a discussion of topics such as sustainable development and biodiversity. Stakeholders also need to be informed about scientific research on such questions as the ecological functions of trees and the point when new growth is considered old growth. Creating Incentives and Encouraging Flexibility Voluntary programs that recognize achievement and provide companies financial returns have been successful at creating incentives for constructive change. Examples of incentives include less-stringent monitoring programs (as now exist in occupational safety rules) and "banking" of voluntarily reduced emissions, or the receipt of tax advantages for such reductions. Some existing voluntary programs that could provide economic benefits to participants are hampered by being too rigid. For example, EPA's Green Lights program will not allow a company to sign up only its lighting-intensive facilities. By being all or nothing, the program has probably delayed some reductions in air emissions that might otherwise have been achieved. Similarly, the EPA's Environmental Leadership Program has only one level of recognition—a perfect compliance record. It is easier for light industries to meet this standard than heavy industries such as pulp and paper. Voluntary programs should respect differences among the various industry sectors and should not be allowed to become command-and-control regulations in the future. For example, the 1993 federal paper-recycling rules (Executive Order 12873) have challenged the industry's preexisting recycling efforts. Voluntary effort recommended by the industry in the 1988 Wetlands Policy Forum deserves special mention here as an opportunity for realizing environmental and economic benefits in forest management. The effort provides for

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Page 138 beneficial use of forested wetlands under a voluntary program of habitat protection in lieu of outright taking under the existing wetlands policy. Such taking not only infringes on property rights and values but also is ecologically counterproductive because it removes any economic incentive to maintain such lands in forest cover. The industry has made some related suggestions regarding the protection of endangered species. Here again, a means of compensating landowners for the effective taking of their property for the common good of protection of species must be developed. Another flaw in the current system is that it does not allow for adequate scientific peer review of decisions surrounding the identification and protection of species. In this respect, it differs from most other regulatory scientific protocols. The application of sound science, in addition to public participation, is an important component for regulatory policies, including those for protection of endangered species. In addition, effective environmental policy by the government requires cost-benefit analyses and consideration of environmental trade-offs. For example, in the paper industry, the trade-offs involved in recycling, which would cause increased reliance on external energy sources (e.g., fossil fuels), must be taken into account. Facility Modernization Another barrier to environmental improvement in the industry has to do with land and groundwater use, zoning, and difficulties in obtaining permits. Modernization of existing facilities sometimes presents logistical problems that are difficult to overcome, yet land-use competition and the perception that industrial facilities pose hazards to surrounding residents discourage the siting of facilities on new grounds, which are generally cleaner and more efficient. Here again, better communication to the public by EPA and industry representatives about the good science behind risk assessment is important. Creating a Climate for Innovation The recent explosion in environmental enforcement in the United States is stifling innovation because the penalty if an innovation fails to meet requirements is too great. A broadening of statutory and regulatory exemptions and tax incentives for innovative environmental technology will have a long-term beneficial effect on the environment. Encouraging Cautious Consideration of Life-Cycle Assessment How are life-cycle assessment initiatives handling forestry issues? The state of the art in setting boundaries for the life-cycle inventory phase seems to focus on resource depletion and does not yet include other proper elements of the forest life

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Page 139 cycle, such as sustainability. Forestry issues are politically hot, so it is difficult to steer LCA discussions away from this one resource and toward the broader issue of extraction of resources in general. Obviously, each use of a natural resource affects streams, biodiversity, and so forth in its own way. In recent life-cycle-based methods, from LCA inventory studies to national environmental labeling schemes, the approach in forestry has been to provide evidence of sustainable regional or national yields (growth greater than or equal to harvest), because the claim of renewability of a resource can be supported only by accounting across a controlled time and land area. Johnston (1997) has reviewed approaches, sources, and uncertainties associated with LCA in the context of the pulp and paper industry. LCA activity is also part of the ISO standards initiative commissioned in 1991 by ISO Technical Committee 207. The intent is to establish some degree of conformity in LCA methodology, as well as in environmental management systems, environmental auditing, ecolabeling, environmental performance evaluation, and incorporation of environmental aspects in other product standards. Recycling initiatives already have had an important impact on the development of LCA. Efforts to establish a formal hierarchy and preferred methods have tended to interfere with otherwise more scientific and technical efforts. Such biases have been seen in drafts of the ecolabel criteria of the European Community, as well as in other practitioners' approaches to the implementation of LCA methodology, and have the potential to damage the credibility of LCA. In future LCA developmental activities, representatives of the forest products industry must be alert to two key sources of bias: the mechanics of allocating environmental burdens between recycled and virgin materials, and prejudices about acceptable methods of waste disposal. In the case of disposal options, the development of a structural hierarchy could blur the objective evaluation of solid-waste management approaches. Solutions that are better implemented for reasons of timing or location could be discarded accidentally. New analyses have been emerging showing techniques and circumstances in which disposal for energy recovery can be better for the environment than after-market recycling. LCA studies are designed with pre-set boundaries. This feature is necessary to manage the required logistical and scientific data gathering and analysis. In the case of the forest products industry, it is important in any LCA to consider how the industry manages its forest resources and the relationship of that management to a particular line of forest products. Because people often react emotionally to the loss of wooded areas, articulating scientific positions is difficult and is a burden other sectors, such as agriculture, do not have to bear. A proper analogy in this case is to an agricultural crop such as corn: no one thinks of cereal production as destroying corn plants. It is well to continue efforts to show that silviculture has many parallels with agriculture and that other resource uses have adverse impacts, too, but these efforts will not be sufficient to put discussions about the forest resource back on a

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Page 140 scientific track. At least one other essential step is to maintain a good track record on silvicultural practices and to make these practices widely known. Forestry practices should not create accountability problems in the inventory phase of an LCA. The evaluation process of LCA should encompass credits for renewable forestry activities and the transformation of nonproductive farmland into productive forestland. However, the state of the art in the impact phase of LCA is not sufficiently developed in silviculture and forest management practices to permit, at this writing, an accurate prediction of the potential future effect of a particular practice on LCA results. There are two energy-related considerations that might further improve the LCA process for forest products. One is to emphasize, as stated before, that more than 50 percent of the energy needs of the industry are satisfied at present by renewable biomass energy. This energy supply is carbon neutral with regard to potential climate change. Incremental energy demands in the industry over and above this are met mostly by fossil fuel. The other consideration is to make use of the energy in recovered paper, when either the amount of recovered paper exceeds, or its quality is less than, the optimal for recycling purposes. Such utilization will be limited in many cases by equipment costs and location. Nevertheless, it is a power-generation alternative, which in terms of LCA could be justified in certain locations and at certain times. A recent example is the change in direction in the German packaging regulations, providing for less recycling and more conversion of waste to energy, in response to hard political and economic realities in that country. Finally, it is important for the industry to be involved in the international development of the LCA methodology. Once international consensus is achieved, it will be difficult to change. The consideration of life-cycle aspects in industrial operations and products can lead to improved practice. However, competing interests from various industrial sectors (e.g., paper and plastic) and the associated economic stakes create a difficult environment for developing scientifically sound, objective criteria for evaluating environmental impacts of manufacturing processes and appropriate regulatory responses. The many questions raised about LCA and the inherent biases in the technique make such assessments inappropriate for regulatory purposes. They are best used for internal decision making in companies. References American Forest and Paper Association (AFPA). 1992. Environmental, Health and Safety Principles. Washington, D.C.: AFPA. American Forest and Paper Association (AFPA). 1994. Pollution Prevention Report. Washington, D.C.: AFPA. American Forest and Paper Association (AFPA). 1995. Sustainable Forestry Implementation Guidelines. Washington, D.C.: AFPA. Also available on the Internet, <http://www.afandpa.org/ forestry/guidelines.html>.

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Page 141 Balzhiser, R.E. 1989. Meeting the near-term challenge for power plants. Pp 95-113 in Technology and Environment, J.H. Ausubel and H.E. Sladovich, eds. Washington, D.C.: National Academy Press. Canadian Forest Service (CFS). 1993. Selected Forest Statistics Canada 1992. Ontario, Canada: CFS. Casey, J.P. 1983. Pulp and paper. Pp. 63-79. Chemistry and Chemical Technology, 3rd ed. New York, N.Y.: John Wiley and Sons. Dence, C.W., and D.W. Reeve. 1996. Pulp Bleaching: Principles and Practice. Atlanta, Ga.: Technical Association of the Pulp and Paper Industry. Folke, J. 1994. Environmental effects from modern bleach plant manufacturing. Paper presented at the National Academy of Engineering International Conference on Industrial Ecology, Irvine, Calif., May 9-1 1. Johnston, R. 1997. A critique of life-cycle analysis: Paper products. Pp. 225-233 in The Industrial Green Game: Implications for Environmental Design and Management, D.J. Richards, ed. Washington, D.C.: National Academy Press. Miller Freeman (MF). 1994. Lockwood-Post's Directory of the Paper and Allied Trades. 1994. San Francisco: MF. Saltman, D. 1983. Pulp and Paper Primer. Atlanta, Ga.: Technical Association of the Pulp and Paper Industry. Technical Association of the Pulp and Paper Industry (TAPPI). 1992. TAPPI Pulping Conference Proceedings. Atlanta, Ga.: TAPPI.