Climate Change Compliance Considerations for an Integrated Pulp & Paper Facility Utilizing Combined Heat & Power: A Case Study, 2009 TAPPI Engineering, Pulping, Environmental Conference

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The New England states, Delaware, New York, New Jersey and Maryland have adopted one of the nation’s first climate change regulatory schemes, which took effect January 1, 2009. While the new Regional Greenhouse Gas Initiative (RGGI) only affects fossil-fueled power generators, its definitions are broad enough to include some manufacturing locations with on-site generation. This paper addresses practical compliance considerations for pulp and paper mill operations when faced with a climate change regulatory scheme, utilizing a case study of an integrated pulp and paper mill which found itself subject to RGGI. Early involvement in the development of state implementing legislation and regulations ensured that public policies supporting combined heat and power, biomass utilization, behind-the-meter generation, and maintenance of manufacturing were woven into the final RGGI law and regulations. Proactive and innovative approaches to compliance ensured that the facility would be able to comply with RGGI while minimizing effects on the facility’s operations and costs. These considerations will be highlighted against the backdrop of pending climate change activities at the federal level.