The Ecology of Industry, 1998. Pp. 101-141
Washington, DC: National Academy Press
The Pulp and Paper Industry
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 materialwood fiberis 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.
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),
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
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.
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
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.
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-
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
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 sludgeboth of which are nontoxic and nonhazardous solid wasteconstitute 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
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 liquoran 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
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
chlorine dioxide that is formed is removed by air or water vapor and dissolved in chilled water for storage. Although these systems are generally self-contained, emission collection systems are provided to collect and scrub any chlorine dioxide that might escape. Sodium sulfate (saltcake), a by-product of the acidification process, is sometimes recycled and used in the chemical-recovery loop. In mills that have such generators, the saltcake can offset some of the sodium and sulfur normally lost to air or water, as solid waste, or in product during the chemical-recovery process. This reduces the amount of sodium and/or sulfur that must be purchased and injected into the recovery cycle.
Chlorine and chlorine dioxide used in bleaching can potentially be emitted from the bleach reactor towers, the bleached-pulp washers, and associated filtrate-collection devices. Because excessive emissions are synonymous with excessive chemical use and cost, these emissions are controlled by continuously improving the control technology for the bleaching process. Improvements include automatic sensing of brightness and other parameters, and the use of algorithms to control the rate of application of bleaching chemicals to the pulp. More recently, most states have put in place additional regulations to control chlorine and chlorine dioxide emissions. To meet these regulations, emissions are forced through alkaline and reductive scrubbers that remove chlorine and chlorine dioxide with high efficiency. Chloroform is not removed by alkali scrubbing, but concentrations of the compound can be lowered by reducing the use of sodium hypochlorite bleach and increasing the substitution of chlorine dioxide for chlorine.
Because of concern about chlorinated organics and the reusability of bleach-plant effluent, research into totally chlorine free (TCF) bleaching processes has accelerated in recent years. (For more information on pulp bleaching, see Dence and Reeve, 1996.)
Meeting Environmental Challenges Head On
In turning wood into paper, the industry has met and addressed several environmental challenges, as described in this section.
Conserving Water and Treating Wastewater
The pulping industry has long been considered an intensive user of water. Early in this century, a typical mill used 60,000 gallons of water to make I ton of bleached paper. Today, new mills can produce I ton of bleached paper with less than 10,000 gallons of water. Process innovations, such as high-consistency bleaching and hot-stock screening, require less water. Noncontact cooling, which segregates water from contamination, has also reduced the quantity of water used. Additional savings have accrued from internally recycling water by using countercurrent washing and by reusing condensates, cooling and sealing waters, ma-
chine white water, and treated effluents. As a result, every gallon of water is reused an average of seven times within the process.
Of course, it takes capital to handle water and to pay for the energy to heat it and move it around. This has been a major factor in the development of new technologies. From a water-use perspective, there are few financial, legal, or physical reasons for the industry to lower water use in paper mills. In some situations, water conservation has been pursued to reduce the costs of waste treatment, which is largely a function of the volume of water treated. The main impetus behind conservation efforts to date, however, has been the general principle of environmental stewardship that less is better.
One of the key strengths of the U.S. pulp and paper industry has been its treatment of wastewater. For the past 30 years, long before they were required by law to do so, U.S. mills have been installing secondary biological treatment systems that reduce biological oxygen demand (BOD) and suspended solids. At locations where land area is available, aeration stabilization and activated sludge technology provide relatively low-cost ways to cut BOD by more than 80 percent. Oxygen-enriched technology became available in the early 1970s in time for use in space-limited facilities. Extensive study and optimization over the last 2 decades have raised the efficiency of these same plants to around 90 percent.
Solid Waste Disposal
Until the early 1980s, disposal of solid waste from pulp and paper production was not a problem. For one thing, the waste is considered nonhazardous by the Resource Conservation and Recovery Act (RCRA) of 1976. In addition, landfill rules required mainly the control of vermin and litter, access control, control of drainage, safe operation, and earthen cover. More recently, new rules on waste characterization, groundwater monitoring, lining and leachate control in some cases, and financial assurance have been added. It is difficult to get a permit for a new landfill today because of the public perception that there is something inherently dangerous about landfills. Therefore, there is an impending capacity shortage at many locations. Such local shortages are driving the exploration of technologies to reduce the volume of solid waste generated or to find new uses for waste.
Some mills, as part of their environmental programs, have developed systems to mix dried primary and secondary waste-treatment sludge with wood waste and bark for use as fuel. In most instances, they have carefully analyzed the waste and the combustion products to isolate potential problems with contaminants and have taken whatever steps were necessary to eliminate them. Nevertheless, opposition to incineration is often stronger than opposition to landfills. Yet, scientifically acceptable incineration systems are necessary for environmentally sound waste management in all industrial sectors. Better communication to the public by Environmental
Protection Agency (EPA) and industry representatives about the good science behind assessment of comparative risks is essential to breaking this deadlock.
Sludge can be used to amend soil, as landfill, as animal bedding, or to produce ethanol or other chemicals. Source reduction through such steps as improved retention of pulp fines can also help reduce waste. However, these and other potential applications are unlikely to negate altogether the need for new landfill capacity.
Controlling Spills and Leaks
An area of significant environmental stewardship in the industry has been in reducing spill and leak hazards. Most mills have already identified the tanks that have the greatest potential to cause injury or other damage in the event of leakage or rupture and have installed secondary containment, sumps, leakage detectors, and other appropriate safety measures. Likewise, leakage monitoring and alarm systems for compressed gases, especially chlorine, are now commonplace.
Energy conservation and the use of fossil-fuel alternatives play an indirect but significant role in environmental stewardship in the forest products industry. The standard practice of using bark and wood waste and black liquor as fuel eliminates about 54 percent of the demand for fossil fuel in the U.S. forest-products industry as a whole, including integrated pulp and paper mills (mills in which the papermaking operation is contiguous with the pulping operation) and nonintegrated mills (American Forest and Paper Association, 1994). Modern kraft pulp mill operations, with the exception of the lime kilns, can satisfy their total steam and electrical energy requirements using black liquor and wood waste and therefore do not require fossil fuels. Wood waste and black liquor are carbon neutral; that is, when burned they cause no net change in the carbon content of the biosphere over the harvest cycle and, therefore, do not contribute to the formation of so-called greenhouse gases. Other key energy conservation measures commonly used today involve reduced water usage; energy recycling and reclaiming in digester areas; systems to improve management and reclamation of low-level heat, for example, from recovery systems; and improved insulation.
The industry has always been interested in reducing the energy needed for pulping. Energy savings not only conserve fossil fuels, but also reduce emissions from the boilers used to generate steam or electricity. Despite its extensive use of self-generated energy, the industry is still the third largest industrial user of fossil fuels in the United States. Much of this energy is used to evaporate watereither from the black liquor prior to burning or from the paper after the sheet is formed on the machine. Processes are being developed and used that utilize low-pressure steam, which was previously vented, to evaporate water. One example is the
steam that flashes off pulp when it is blown from a digester after cooking. This steam, called blow heat, can be routed to heat liquor in blow-heat evaporators. Low-pressure steam can sometimes be converted economically to high-pressure steam by vapor recompression.
On a paper machine, it is much less energy-intensive to remove water from a paper web by mechanical means than by evaporation. As much water as possible is squeezed out of the web in a paper machine press section, but the sheet is still 55 percent water. Extended nip pressing and impulse drying are novel mechanical dewatering methods that have emerged recently, and the future surely holds others. The general approach to energy reduction could include improvements in overall management of the reuse of low-level energy in both pulping and papermaking. Also in the pulping area, using nonfossil fuels in the lime kiln, or eliminating the kiln by developing autocausticizing processes, would contribute additionally to the fossil-fuel independence of the kraft process.
Recovered paper is also a great potential source of energy. Paper has significant heat value, burns cleanly, and is carbon neutral. Paper that is contaminated with materials (e.g., plastic) and difficult to recycle can be used as fuel to offset the use of fossil fuel. Because more locations are available for burning recovered paper than for reprocessing it, collection logistics can be simplified and transportation energy requirements reduced.
One of the ironies of the industry's attempt at environmental stewardship relates to odor control. It seems that when odor control equipment is installed at a kraft mill, the number of complaints about bad odors increases. People become accustomed to an odor when it is always around but notice it when it comes and goes. Today, with heightened environmental consciousness, people associate the smell of an industrial operation with exposure to a hazard. Hence, there will be increasing pressure to achieve and maintain odor control, possibly in excess of what is required by law. Technology offering superior odor control will be at a premium. The need for low-cost backup odor control devices is also apt to grow in the industry, whether or not they are required.
Current and Future Trends Shaping
Technology in the Industry
Restrictions on the supply of wood will increase its cost. Cost increases, in turn, will make recycled product and process technology relatively more attractive. They will also raise interest in improving pulping processes to conserve cellulose and increase yield through catalytic pulping with anthraquinone, by defiberizing with less delignification through solvent pulping, or using new mechanical pulping technologies. In addition to having less desirable end-product charac-
teristics, the mechanical processes do not compare well with the kraft process because of their large requirements for fossil fuels and production of waste streams for which commercial treatment technology has only recently been developed. Solvent pulping systems require more development to resolve strategies for using by-product carbon and to improve their overall economic feasibility. Comparisons between technologies need to be done on the total-mill concept (i.e., by looking at how each technology affects the economics, safety and environmental effects, and material and energy balances in all parts of the mill).
Of course, all technologies designed to improve the resource and economic efficiency of pulping and papermaking must pass environmental muster. Most of the first part of this paper has described the strides that have been made already by the industry to control pollutants. The remainder of this section describes new developments and trends that might affect the industry's environmental stewardship in the future.
The cornerstone of the minimal-impact philosophy is the effluent-closed mill. The common wisdom is that effluent closure requires eliminating chlorine from the bleach plant because of the corrosivity of aqueous chloride. This has led to the development of closed kraft TCF bleaching, which is not a field-proven process and might cause contaminants to build up over time. "Even with the elimination of chlorine, methods for controlling or purging the build-up of other materials, anionic trash for example, need to be found and improved upon" (Technical Association of the Pulp and Paper Industry, 1992). The conventional wisdom about the need to eliminate chlorine might not be achieved by any mill through effluent closure. Contaminants will still have to be managed as solid waste, as emissions into the atmosphere, or with the outgoing product. It might be possible to manage chloride levels of corrosion rates with alternative technologies. Separate chemical-recovery systems specifically for handling bleach-plant chemicals could be developed (Folke, 1994).
Regardless of the methods developed, the concept of closure can be deceptively appealing. It appears to minimize water use, lowers energy consumption, and lowers waste impact. Ozone, peroxide, and enzymatic bleaching systems are alternative processes under development to minimize concerns about chlorinated organic trace by-products, such as dioxin. However, little is known about the composition of the effluent from these newer processes or their potential for environmental or human health impacts. More study is needed on ways to trace chlorinated organics or reduce their generation in wastewater or in process streams. Some approaches that have been considered are biological or chemical dechlorination, wet oxidation, ultraviolet irradiation, and electrolytic treatment, as well as methods utilizing natural processes such as spray irrigation, overland flow, and use of either natural or man-made wetlands.
What is the industry likely to do with conventional emissions and discharges in the future? As far as water is concerned, aesthetics are likely to receive greater emphasis; in fact, the minimal-impact mill will be expected to have little noticeable environmental impact as far as the public is concerned. There is likely to be an increasing number of limitations placed on incremental allowable stream color, especially at locations near recreational areas. Therefore, research into lower-cost color removal techniques will continue.
Concern about deforestation (and public misperception that the forest products industry is a contributor to it) and about the worldwide production of solid waste have put paper at the top of the list for recycling efforts in developed countries. Of course, internal (intrafirm) recycling has long been practiced. Indeed, every paper mill has a repulper to handle its own waste. Now, the key interest is in post-consumer recycling. There is currently a glut of recycled fiber, because the capacity to collect recovered paper is greater than the capacity or technology to process it into products of any given level of quality, which in turn exceeds the market demand for most recycle-grade paper. In addition, the cost and energy requirements to process recycled fiber into high-quality grades exceed those for processing virgin timber. Another important factor is the cost of collecting and transporting recyclables to mills equipped to process them.
The U.S. pulp and paper industry and its customers are facilitating the development of recycling technology and capacity. They are doing this through a voluntary wastepaper recovery target (an effort of members of the AFPA) and through purchasing specifications for minimum recycle content on the part of many customers, most notably the federal government. The industry, through AFPA, committed itself to recovery for recycle and reuse 40 percent of all paper used by 1995. This goal was met 2 years ahead of schedule, and the industry has recently established a new goal: 50 percent recovery by 2000. The Technical Association of the Pulp and Paper Industry (1992) projected that meeting the year 2000 goal would essentially require a doubling of the 1985 recycle capacity by 1995, assuming no change in processing technology. The principal technologies used by the paper recycling industry today are limited to classification at the point of collection, limited plastics and metal removal at the point of remanufacture, and surfactant deinking. Management of the solid waste generated as a result of recycling efforts presents a significant technical challenge. Research to explore a variety of alternative uses for this waste, including as fuel, compost, and feedstock for ethanol production, is ongoing.
The expansion of paper recycling will increase interest in deinking and rebleaching technology, used to remove color from the fiber, and in lowering the cost of doing so. Improvement will also be needed in the separation and disposal of deink sludge. Innovation in ink and copier-toner technology also holds promise for reducing the toxicity and amount of deink sludge.
It is widely believed that the trend in the pulp and paper industry is to move away from constructing virgin pulp and paper mills in "greenfields" (new, untouched locations) toward locating recycle-intensive "mini-mills" closer to urban population centers, where the recyclables are collected. If the future unfolds this way, disposal of the large amounts of deink sludge will have to compete with municipal waste for space in landfills. Finding new uses for this sludge is critical. To date, deink sludges, which are made up primarily of short fibers and clays, have proved to be superior landfill cover materials, adsorbents, and aggregates. New chemical and mechanical operations to deal effectively with the separation of useful materials from contaminants in recovered papers are urgently needed. A consequence of the development of urban mini-mills will be the reduction in recycle fiber available for use in remote, larger paper mills. A national standard for recycle content, therefore, might be difficult to achieve.
The development of new or improved technologies for pulping, bleaching, papermaking, and chemical recovery can potentially further improve the efficiency of resource utilization in the pulp and paper industry. Alternative bleaching processes that reuse bleach plant wastewater would reduce water use. The development of black-liquor gasification technology could improve the safety and efficiency of the chemical-recovery process and reduce emissions of air pollutants. Finding alternative uses for the solid waste resulting from increasing production of recycled paper (e.g., deink sludge) will also help reduce waste.
However, good environmental practices must be based on science. They must proceed with the same deliberation and objectivity as any other technical endeavor. Efforts to find new uses for waste materials need to take into account other resources used. Even alternatives that are less acutely toxic could cause greater environmental damage, in terms of wasted energy or the production of a larger amount of less-toxic pollutants. Finding new uses for waste and substituting less-toxic materials for ones that are more toxic make sense as general principles but should not be interpreted as inviolable rules.
In undertaking major capital projects, companies in the industry minimize the possibility of not addressing critical environmental concerns by having the projects reviewed within the organization by a group responsible for environmental oversight. Life-cycle assessments, discussed later in this paper, could guide internal corporate decision making on environmental issues. However, there is much work to be done, such as getting the data necessary to define boundary conditions for reliable life-cycle assessments.
Regulations and Standards
The inefficiency of approaching environmental issues in a piecemeal manner is glaringly evident from the last 2 decades of environmental initiatives. At times,
money was spent on technologies that later were found to be inadequate. Sometimes, solutions created other, unforeseen problems. At other times, the opportunity to solve multiple problems simultaneously with a single but different technology was missed. Some companies, using long time horizons, are attempting to accurately predict what entire plants will need in terms of process and environmental control for the next 20 years or more. Even this more methodical approach is problematic, however, because regulatory requirements will change in response to changing science, economics, and public demand. Creating no environmental impact is technically impossible. Most human activities alter the environment in some way. "Minimal impact" might be a realistic goal, although its definition is vague. Indeed, this vagueness offers the industry an opportunity to work with various stakeholders to reach common ground on which to build sound environmental policy and strategies.
Regulators, industry, and other stakeholders should work in close cooperation to set long-term environmental goals. Such cooperation is currently lacking in the U.S. regulatory efforts. Allowing the industry to experiment with alternative means of meeting these goals would be a positive departure from the current command-and-control approach.
Regulatory Trends: Where We Are Today
Prior to the creation of EPA by Congress in 1970, the pulp and paper industry in America operated under an assortment of state regulations of varying stringency. As early as the end of World War II, industry environmental performance was well ahead of government initiatives. The National Council for Air and Stream Improvement of the U.S. pulp and paper industry began disseminating environmental technology to its members in the 1940s. By the 1960s, most new mills were built with both primary and secondary wastewater treatment, as well as electrostatic precipitators on boiler stacks and scrubbers on lime kilns and smelt tank stacks, even though they were not required by law in most localities. Since the 1970s, however, federal regulations, administered by EPA and individual state authorities, have grown exponentially (Figure 3), becoming the dominant force shaping the industry's response to environmental issues.
Each decade has heralded a new regulatory wave. The 1970s might be thought of as the "framework decade," in which the basic federal structures of delegation to the states and permit-granting systems were laid out and tested. The Clean Air Act of 1970, for example, set limits on ambient air contamination and required implementation plans from the states, including permit-granting rules and programs for solving ambient-air-quality problems. The Clean Water Act of 1972 established the National Pollutant Discharge Elimination System, which required every manufacturing and municipal waste-treatment facility to obtain a permit limiting discharges. The Endangered Species Act of 1973 mandated protection of threatened and endangered species via the U.S. Fish and
Wildlife Service's rulemaking process. The Resource Conservation and Recovery Act of 1976 brought solid and hazardous waste under uniform federal regulation for the first time, and the Toxic Substances Control Act of 1976 addressed use of chemicals.
The 1980s might be considered the "land decade." It was during this period that federal authority expanded beyond protection of ambient air and water. The
Comprehensive Environmental Response, Compensation, and Liability Act of 1980, popularly known as Superfund, and the Superfund Amendments and Reauthorization Act of 1986, went far beyond the original scope of the Resource Conservation and Recovery Act, covering accidental releases, leakage from underground tanks, and remediation of disposal sites. There was also a shift away from the traditional regulatory process of involving solely technical professionals in the industry and government toward greater citizen involvement in permit hearings and lawsuits. The 1980s were also characterized by increased pubic awareness of environmental issues.
The 1990s began with reauthorization of the Clean Air Act, which greatly expanded the list of regulated air pollutants to include toxic compounds. An upshot of this has been concern that air controls are merely transferring pollution from air to water and soil. This has led to the so-called cluster rules and multimedia limitations now under development. Other regulatory and voluntary initiatives, spurred by concern over global environmental effects, are now directed increasingly at pollution prevention, reducing the discharge of pollutants in general, and at a long list of individual substances, including carbon dioxide. It looks as if this will be the pattern for the rest of the decade, and it seems apt to dub it the ''prevention decade."
The following is a summary of the environment-related regulations affecting the pulp and paper industry in the United States today:
· Air Stack emissions of particulate matter, sulfur oxides, nitrogen oxides, carbon monoxide, volatile organic compounds, and TRS are usually regulated by renewable permit. Numerical permit limits are the more stringent of either technology-based or air-quality-based limits. Technology-based limits derive from the typical performance of some type of control, such as best available control technology, whereas air-quality-based limits derive from the maintenance or improvement of the quality of the ambient air or the prevention of significant risk to health. Standards also exist for odors and effects on visibility. Intentional discharge of chlorofluorocarbons into the atmosphere is prohibited. In 1995, EPA finalized maximum-achievable control technology (MACT) standards, which established limits for a number of hazardous air pollutants. According to the current schedule, chemical pulp mills will be required to comply with these limits by 1998. The combination of these standards with pending revisions to effluent guidelines is referred to as the cluster rule.
· Water Discharges of conventional pollutants, such as BOD, suspended solids, corrosives, oil and grease, fecal coliform, and 127 pollutants designated as toxics, are open to regulation through permit renewals, as are discharges of other nonconventional pollutants, such as color or chemical oxygen demand and stormwater outfalls. Permit limits are either technology based (mass allowed per unit of product) or water-quality based (not allowed to exceed or worsen noncompliance with federal or state water-
quality criteria, whichever are more stringent). Water-quality criteria limit exposure of people and aquatic life to harmful constituents. Discharge of oil in any visible amount is prohibited. Effluent guidelines for the pulp and paper industry are currently being reviewed by EPA as part of the cluster-rule process. These standards will substantially increase the stringency and scope of existing technology-based standards as well as establish numerical limits for several compounds, including 12 chlorinated organics not previously regulated.
· Solid and hazardous waste. Most solid-waste disposal sites must obtain permits and follow specific management procedures. Federal standards exist for municipal waste disposal. Currently, industrial-process waste is regulated by the states. Hazardous waste, which is listed as hazardous according to either its chemical composition or any of four characteristics (toxicity, reactivity, corrosivity, ignitability), must be handled specially and treated before disposal. Leachate from new waste disposal sites must be collected and treated, if necessary, before release. Underground storage tanks must be tested for leakage, and any leakage must be remediated. Groundwater that might be affected by waste disposal or underground storage must be monitored and remediated, if necessary, to meet certain criteria. Old disposal sites that EPA determines pose a threat to human health or the environment must be cleaned up.
· Protection of ecosystems. Recent stringent interpretation of the Endangered Species Act and the Clean Water Act has come in conflict with traditional private-property rights. Controversies have resulted over such issues as protection of endangered species (e.g., the northern spotted owl in the Northwest) and use of property purchased before it was designated as wetland. The interpretation of these regulations and how they affect the forest resource is of concern to the industry today.
· Health and safety of products. Food packaging is regulated by the U.S. Food and Drug Administration and the U.S. Department of Agriculture (USDA) because of the potential for migration of substances from packaging into food. Food-packaging rules are contained in the Code of Federal Regulations (CFR), Title 21, mostly under Sections 174 and 176. USDA also regulates packaging components that could come into contact with meat or poultry. The agency relies on provisions in 21 CFR plus a certification system for suppliers of packaging.
Regulations also require that equipment containing polychlorinated biphenyls (PCBs) not be located in a plant such that leakage could contaminate the product. They also require that the concentration of PCB in the product not exceed 10 ppm. These regulations, in effect since the 1970s, are not an issue any longer for either virgin or recycled papers. Twenty years of monitoring indicates a clear overall reduction of PCBs to levels far below 10 ppm.
The Industry's Record
The industry considers its record of compliance with U.S. regulations to be excellent, especially considering the volume and complexity of the rules it is subject to. Many infractions are administrative in nature (e.g., failure to file the proper notifications or forms) or result from poor communication and follow-up on environmental needs. Nevertheless, enforcement of such infractions is being pursued with increasing vigor, so the record could wrongly imply declining performance. Many companies have set up environmental management systems that include environmental training for nonenvironmental professionals and environmental auditing to reduce the opportunity for infractions of this kind.
A partial list of the industry's environmental accomplishments is provided below (American Forest and Paper Association, 1994). The industry
· spent over $1 billion per year in the 1990s on pure environmentally related capital, expenditures that in 1991 and 1992 represented almost 20 percent of total capital expenditures;
· reduced in-mill water usage and the volume of effluent generated in the production of a ton of paper by over 70 percent since 1959;
· decreased the amount of BOD in effluent from 94 pounds per ton of product in 1959 to 8.2 pounds per ton in 1988;
· lowered the amount of total suspended solids discharged per ton of product by 80 percent between 1979 and 1988;
· reduced the proportion of sludge going to landfills and lagoons by 16 percent between 1979 and 1988;
· cut discharges of dioxin by 90 percent between 1988 and 1992, limiting the combined generation of the compound by all U.S. mills to less than 4 ounces per year;
· performed widespread process changes sufficient to decrease the amount of chlorinated organic compounds in effluent by 30 percent since 1988;
· cut use of elemental chlorine by 34 percent since 1986, with expectation of a 50-percent reduction by 1996;
· planned to increase dramatically the use of alternative bleaching chemicals, including chlorine dioxide and hydrogen peroxide (a 60-percent projected increase by 1996) and oxygen (a projected 90-percent increase);
· decreased releases of TRS by 73 percent between 1968 and 1980, as kraft pulping capacity was increasing 36 percent (By 1990, the reduction was estimated to be over 90 percent, despite a 75-percent increase in pulping capacity.);
· lowered total emissions of sulfur dioxide by 30 percent in the 1980s as the volume of paper manufactured increased by the same percentage, resulting in a 50-percent reduction in emissions per unit of production;
· was three times more successful at lowering sulfur dioxide emissions than U.S. industry as a whole;
· curbed growth of mill boiler fuel consumption sufficiently to produce a 15-percent decrease in the per-unit-of-production release of oxides of nitrogen during the 1980s;
· steadily lowered per-unit releases of acetone, chlorine, and chlorine dioxide into the air between 1988 and 1991, as chemical wood production increased 8 percent; and
· dropped per-unit emissions of chloroform into the air by 30 percent between 1989 and 1991.
Regulatory Trends: Where we are Headed
On the U.S. regulatory scene, the greatest impetus will be to clarify remaining issues regarding requirements under the Clean Air Act Amendments (CAAA) of 1990 and integrate them with the pending cluster rule and, eventually, with the reauthorized Clean Water Act.
Perhaps of greatest concern to U.S. industry in the near future are methanol and chloroform emissions, two of the hazardous air pollutants (HAPs) identified for regulation under the CAAA. The emissions of these compounds are in decline. Chloroform emissions are reduced by using molecular chlorine and hypochlorite in bleaching; methanol is reduced by capturing it, along with noncondensible gases from pulping, liquor evaporation, and pulp washing, and then incinerating it. Most mills in the United States already have made changes to achieve reductions. If MACT is defined as the emissions level achieved by the best 12 percent of the industry, most U.S. mills will have to go further to meet the new standards.
The CAAA mandates that the residual health risk from HAPs, after MACT has been applied, be analyzed to see whether further reductions are needed to protect public health. Sources of HAPs will have to be further reduced depending on what level of risk is considered acceptable.
Risk assessment is often used by U.S. agencies to deal with specific environmental problems such as residual risk. Risk assessment, however, has not been adequately used by the government to prioritize environmental concerns. Meanwhile, the list of risk-based concerns continues to grow, and with it the enormous burden of doing proper risk assessment.
Concerns about regional air pollution have rekindled interest in two of the five criteria pollutants: sulfur oxides (and their contribution to acid deposition) and nitrogen oxides (and their contribution to regional levels of photochemical oxidants). Studies by EPA over the past 5 years suggest that nitrogen oxide emissions might play a greater role in the formation of photochemical oxidants than previously thought. The upshot of this finding is that many small boiler operations in regions that do not attain the current ambient-air-quality standard for ozone might have to install reasonably available control technology for reducing
nitrogen oxides emissions. Installing such technologies, such as low-nitrogen-oxide burners or steam injection, will add costs due to the need for retrofitting and from associated losses in energy efficiency.
The trend today is for regulators to limit the choice of manufacturing process as a way of reducing pollutant emissions to all media. This is a shift away from the practice of attempting to control emissions to specific media at the end of the pipe. This trend is driven by the concern that the requirements of the CAAA might cause emissions of certain chemical compounds to be shifted from air into water or, as solid waste, into soil. In December 1993, EPA proposed a cluster rule that in effect limits the companies' ability to use process pulp bleaching. The pulp and paper industry was the first industry targeted for such a rule, which combines the requirements of the MACT standards with revised effluent guidelines under the Clean Water Act. Although EPA has for many years issued technology-forcing regulations, the technology being forced was for end-of-pipe pollution control. The new rules are the most significant effort undertaken by U.S. environmental regulators to force the type of manufacturing technology used. The cluster rule is exemplified by standards for all bleached-paper-grade kraft and soda operations based on the use of either oxygen delignification or extended delignification, and complete substitution of molecular chlorine with chlorine dioxide.
The Current Regulatory Process
The current regulatory approach is inherent in legal mandates passed on to EPA by Congress, which too often bends to environmental fashion rather than using scientific evidence to set a course of action for the long term. Constant jumping from one crisis to another compromises the success of existing programs, leads to regulatory overlap and duplication of effort, and confounds capital planning by affected enterprises. The current cluster-rule effort in the United States is an example of a belated and ad hoc attempt to resolve such problems, but it only treats one case, and in a crisis atmosphere (under court order) at that. There is every reason to expect more of the same unless certain barriers are overcome, as discussed more fully in the last section of this paper.
A quasiregulatory force affecting all U.S. industries today is the threat of citizen-action lawsuits based on various environmental statutes or on allegations of injury. This activity will increase not only because of heightened media attention to the environment, but also because of the ever-increasing ability of science to relate cause and effect. The desire to prevent real harm to anyone and avoid the cost of defending against false allegations will drive companies to tread ever more carefully in environmental matters.
Nonregulatory Environmental Pressures
In addition to these expected regulatory activities, three relatively new nonregulatory forces are increasingly driving environmental effort and expenditures in the industry. The most significant of the three is the marketplace itself. This "green market," already heavily influential in Europe, will increasingly favor products that are biodegradable, low in toxicity, and reusable. Most of all, it will favor recyclability and high-recycled content.
Late in 1993, President Clinton ordered the executive branch of the federal government (i.e., nearly all federal offices) to specify a minimum amount of after-market recycled content in all paper it purchases (Executive Order 12873. Oct. 20, 1993). The requirement for recycled-fiber contents starts at 20 percent in 1995 and increases to 30 percent by 1999. Other major users of paper might adopt similar criteria.
As recycling and the capacity to process recycled material grow, new environmental demands will arise. The obvious one is that the amount of deink sludge will increase. In addition, new recycling mills are likely to be located closer to population centers. Thus, the impact of these operations on air and surface waters could add to environmental burdens in these areas, and mills will have to account for these potential impacts. Another adverse aspect of recycle-fiber processing is that it does not supply its own energy in the form of biomass, as does virgin-fiber processing.
Some believe that reducing environmental impacts is synonymous with economic savings and that environmental improvement would happen by itself if industrialists took a closer look at recycling and conservation options. Undoubtedly, there are some unrealized opportunities here, but it is easy to overestimate the degree to which such incentives can substitute for regulations. After all, it has always been the business of engineers to look continually for ways to increase net profit.
A broader version of this principle is embodied in the concept of full-cost accounting, which adds aesthetic, ecological, depletion, and contamination values to the cost of a resource. There is no consensus today about how these values would be established or how the accounting would work. The only way full-cost accounting per se can drive environmental improvement is if it results in increased profit. Unlike conventional costs, which are based solely on labor and material supply and are therefore self-determining, these new values would have to be established and funded by some national or international regulatory authority. To address regional and local environmental issues, one would have to either have local variations in values or create a hybrid with the current regulatory scheme. In any case, no one can say such a system would automatically be less contentious or complex than the existing framework.
A significant second force is increasingly stringent environmental regulations in countries around the world. Some countries limit the environmental effects not only of their own products, but also of imports. Such regulations might also take
the form of limitations on the amount of pollutants emitted or discharged per unit of product at the point of manufacture. They might require ecolabels, which are then used as trade barriers.
The third force, which will become manifest in 2 or 3 years, is international environmental standards, which are currently being developed by the International Standards Organization (ISO).
For all of these reasons, unless there is a downward shift in the priority of environmental issues relative to other public concerns, the industry should expect equally or even more complex rules, ever-tighter regulatory restrictions, and a high level of competition in the green market. This will lead, in turn, to periodic surges in capital costs. Environmental operating costs should increase accordingly, and the industry can expect these costs to consume a larger portion of its resources in the years ahead.
Environmenttal Performance Metrics
The stringency of environmental regulations is increasingly linked to the measurement used. In the early 1970s, environmental measurements by companies consisted almost entirely of spot tests of emissions and discharges such as semiannual stack tests and daily effluent BOD, with a smattering of required ambient tests (e.g., river oxygen and ambient particulates). Regulators assumed that the spot tests were sufficiently representative of continuous performance. Independent verification or auditing of results was reserved for enforcement cases. Knowledge of the condition of the ambient environment was left up to the state and federal governments. Individual substances that either could not be detected by existing methods or were not believed to be present were not regulated. This relatively simple approach has changed dramatically over the last 20 years.
Emission and discharge monitoring technologies have become very sophisticated. As continuous and automated methods for determining pollutant concentrations in the environment and in organisms become more reliable, they are required in permits. Most significantly, as measurement sensitivity improves, substances can be found at lower concentrations. As a result, substances are found in effluents and emissions that had not previously been known to be present. If such a substance is believed environmentally significant, it is added to the lists of regulated substances. Perhaps the best-known example of this is dioxin, which can now be measured at concentrations as low as one part per quadrillion.
Mathematical modeling is used increasingly to estimate exposure to environmental contaminants. The movement of pollutants from sources to receptors has been difficult to measure because it is time dependent and because the ambient environment is vast and variable. Because of this, there has always been a gap between the concentration of pollutants predicted to exist in exposed organisms and the actual amounts found. There is therefore a need to improve mathematical modeling of the environment, for example by macromodeling media to
determine exposure to pollutants; micromodeling the assimilation and metabolism of pollutants by organisms; and verifying model performance using measurement data.
The quality of assessments of exposure to pollutants, as determined by emissions testing and modeling, and of assessments of impacts on health, as determined by epidemiological study and pharmacokinetics research, are gradually converging. The overall result is an increased ability to relate an industrial activity to a particular health or ecological effect.
The net effect of these advances on the industry has been refinements in discharge limitations that are based on impact (as opposed to those based on available technology). It is now possible to calculate (with uncertain accuracy) a maximum-allowable rate of discharge of a pollutant using a defined maximum-allowable concentration of the pollutant in an organism. Thus, the measurement (e.g., testing for pollutants in fish) and limitation of pollutant levels in organisms constitute an increasingly common feature of permits. Many bleached-pulp mills, for example, test fish regularly and frequently for dioxin. State regulators then compare the results of these tests with the allowed maximum levels and decide whether to set permit limits.
Among the public, terms such as total, eliminate, and zero are often used in relation to environmental effects with no appreciation of the fact that they are meaningless outside the field of pure mathematics. As emissions and concentrations of contaminants and observable effects approach the limits of detection, it becomes difficult to distinguish real improvement from measurement "noise." This is important as it relates to the above-mentioned need for better setting of priorities.
Environmental performance is not measured solely in the ambient environment, of course, but is also indicated by business practices. As a way of proactively improving environmental performance, some firms are defining numeric parameters that measure gross compliance with the law and company policy (auditing), gross effect of specific products and their manufacture on the environment (life-cycle assessment and ecolabeling of products), and the effectiveness of environmental management systems. None of these approaches is yet the subject of regulation in the United States, even though many domestic, foreign, and international organizations are participating in programs to define and use such parameters to effect improvement in environmental performance and public relations.
Elements of these approaches already appear in voluntary programs such as CERES (Coalition for Environmentally Responsible Economies), PERI (Public Environmental Reporting Initiative), and the Japanese Keidanren, and they might eventually appear in the ISO international environmental standards.
The concept of product life cycle recognizes that the environmental impacts of a product extend beyond the product's disposal when its useful life is over. A
clear profile of the environmental impacts of a product can be obtained by carrying out a life-cycle assessment (LCA). The assessment consists of a life-cycle inventory (a quantification of energy and raw materials requirements, and environmental releases throughout the life cycle of the product), a life-cycle impact analysis (a characterization and assessment of the effects of environmental loadings identified in the inventory), and a life-cycle improvement analysis (a systems evaluation of the needs and opportunities to reduce environmental impacts).
The life-cycle concept is not new to the forest products industry. A renewable raw material resource seems intuitively superior to the alternatives. The same is true for a resource that also provides for the self-generation of a majority of the industry's process energy. These benefits were understood long before life-cycle terms were applied to them. Now, it is important that the quantitative methods being developed for LCA accurately reflect these unique circumstances of the industry.
Life-cycle inventory studies were conducted originally in the United States and in Europe as an outgrowth of the oil crisis of the early 1970s. As the energy crisis faded, interest in the life-cycle concept waned. It was not until the mid-1980s that life-cycle inventory approaches reemerged. In the 1990s, LCA expanded rapidly as a result of a converging set of technical developments, business interests, and public policy and information needs. Directives by the European Commission's Directorate of the Environment concerning packaging, liquid-food containers, ecolabeling, and so forth played a key role in spurring international interest. The impending use of LCA as a market-based regulatory tool by this key economic bloc has piqued worldwide interest.
Interest is especially high in competing industry sectors, such as plastics and paper, in which the relative outcome of an LCA depends heavily on which factors are included in the inventory of effects and on the methodology used for the LCA itself. The marketing establishments of competing industries, especially those in consumer products, see LCA and similar ecoprofiles as tools to integrate environmental science into marketing efforts. On the plus side, such tools permit technically based product differentiation by environmental attributes. Having numerical results that lead to a ranking system for comparison of products is very appealing to marketing interests in general. Obviously, however, there is the potential for the LCA to be misapplied to secure market advantage, which underscores the need for a consistent and technically sound approach.
There is a gradually emerging consensus in some developed countries on what should be included in a life-cycle inventory. As of this writing, however, no complete LCA methodology is known to have been officially adopted in any jurisdiction, either by an agency of government or by a standards-making or certifying body. Nevertheless, the world is moving in that direction, and there is much international activity along those lines.
Since 1990, an American and European group, the Society of Environmental Toxicology and Chemistry (SETAC), has played a major role in the development
of life-cycle applications. SETAC's efforts have helped define the limits of what can be done in LCA and have been picked up and further developed by many other environmental organizations, such as EPA and ISO.
Recognizing the inadequacy but growing importance of LCAs, AFPA is sponsoring a life-cycle inventory study in the grocery-bag sector to reflect intrinsic characteristics of paper products and, with NCASI, to enhance the present LCA methodology. The results should help overcome difficulties and delays in reaching agreement internationally on a proper and sound impact-assessment methodology.
Another objective of the AFPA study is to compare in an unbiased manner various attributes of paper bags with those of plastic bags. For this purpose, a peer review group of experts and stakeholders from both industries was formed and has been reviewing the study from its inception. This review group is a model of transparency in design and purpose. So far, the group has accepted the study's objectives, boundaries, scope, and database. A goal of this effort is to address a key inadequacy of LCA: The method does not link discharge inventories to actual environmental impacts. Until this shortcoming is remedied, LCA might actually serve as a barrier to real environmental improvements.
The Changing Corporate Culture
Environmental concerns are currently a major issue for the pulp and paper industry, and they are expected to remain so far into the future. Environmental performance dominates the discussion about the industry, both from a public policy and a public relations standpoint. The industry recognizes that its continuing success will depend on a healthy environment. Through the years, the industry has worked hard and invested much to improve and to minimize its impact on the environment, and it has made significant progress.
What drives this progress in environmental stewardship? Government mandates, advances in technology, and better understanding of the impacts of manufacturing processes on the environment have contributed to many of these advances. Also playing a role have been voluntary efforts by the industry.
There are many examples of voluntary industry programs that benefit the environment. One such program, mentioned above, has committed the industry to recovering for recycling and reuse 50 percent of all used paper by the year 2000. Meeting this commitment will ensure that by the year 2000, 40 percent of all fiber used to make pulp and paperboard will be from recovered paper. This figure is up from 25 percent in 1988. Many pulp and paper companies also signed on to the 33/50 program that called for reducing the discharge of 18 toxic substances into the environment by 33 percent by 1992 and by 50 percent by 1995.
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-
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.
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 orderthat 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
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 demandsprotection of the environmentand provide what the public needsa strong economythe 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-
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.
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 impracticalityoften impossibilityof 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
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 recognitiona 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
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.
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
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
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.
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>.
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.