These three White Papers from the American Forestry and Paper Association (AF&PA) advocate a risk-based exemption for EPA Maximum Achievable Control Technology (MACT) rules. EPA cited the papers in its proposed rule entitled "National Emission Standards for Hazardous Air Pollutants for Brick and Structural Clay Products Manufacturing; and National Emission Standards for Hazardous Air Pollutants for Clay Ceramics Manufacturing," on which it is now accepting public comments. AF&PA White Paper on Concentration-based De Minimus Applicability on Exemptions in the Wood Products MACT AF&PA White Paper on Enforceable Agreement Allowing Risk-based Delisting of Sources in the Wood Products MACT AF&PA White Paper on Risk-based De Minimus Applicability Exemptions in the Wood Products MACT Back to Watcher Story "OMB Hijacks Clean Air Standards"