This week, the dark money group American Future Fund [3] (AFF) launched a misleading ad attacking Democratic U.S. Senate candidate Tammy Baldwin for supporting legislation that would allegedly shut down eleven paper mills and lay off 7,500 paper workers in the state, ignoring Baldwin's negotiations to protect Wisconsin jobs that might be affected by the rule and her strong record on trade policy and manufacturing.

The ad refers to Baldwin's vote against an effort to block the U.S. Environmental Protection Agency's Boiler Maximum Achievable Control Technology (MACT) rule, which would tighten the pollution standards for industrial, non-utility, coal boilers. However, it relies on sloppy data and fails to acknowledge Baldwin's efforts to protect Wisconsin manufacturing jobs, particularly in the paper industry.

According to the EPA [4], the MACT standards, currently undergoing interagency review, "are meant to protect Americans from mercury, soot, lead and other harmful pollutants released by boilers and incinerators that can lead to developmental disabilities in children, as well as cancer, heart disease, aggravated asthma and premature death."

A key claim in the ad comes from an Op-Ed article by Jeff Landin of the Wisconsin Paper Council, who used figures from a 2010 study commissioned by the American Forest and Paper Association and Fisher International, a consulting and information services firm to the pulp and and paper mill industry. The ad extrapolates findings of the industry study which noted "at risk jobs" in the Midwest from the regulation. The study, according to Dr. Charles Kolstad [5], Chair of the Department of Economics at the University of California at Santa Barbara, "purports to estimate the increased costs borne by the industry from the proposed regulation, the number of mills that may be shut‐down from the rule, and the number of jobs that may be lost from the rule. Unfortunately, the methodology is fundamentally flawed in many respects; thus the results reported are useless." He added that "If I were grading this, I would give it an F. The economics is all wrong (lack of an incidence analysis or acknowledgement of its importance; failure to draw on the relevant literature), which of course would be my main concern." Laurie Johnson of the Natural Resources Defense Council echoed [6] this statement: "a cursory examination reveals gross exaggeration of compliance costs and employment impacts, and a lack of understanding of even introductory-level economics."

The ad also does not note that Baldwin met with EPA's Lisa Jackson this spring to press for an extension to implementing this rule so that paper companies in Wisconsin and elsewhere can spread the associated costs of the rule over time, a move requested by the industry. The EPA is now in the process of updating the rule based on analysis of data and input from states, environmental groups, industry, lawmakers and the public. According to the EPA, the "proposed changes would achieve extensive public health protections while increasing the rule's flexibility, which would cut the cost of implementation by nearly 50 percent from the original 2010 proposed rule. The boiler standards are currently undergoing interagency review led by the Office of Management and Budget."

The ad is attacking one of Baldwin's strengths, her voting records on manufacturing issues. Baldwin has voted against every major job-killing free trade agreement proposed by any administration, Republican or Democrat. She introduced and passed the CHEATS Act which works to protect the state from unfair trade policies with China, by allowing the U.S. to impose duties to offset subsidized Chinese imports. According to the Economic Policy Institute [7], Wisconsin lost over 52,000 jobs from unfair trade policies with China. The Chinese government provided $33.1 billion in subsidies to its paper industry form 2002 to 2009, making it the world's largest producer of paper and paper products.

AFF is organized as a 501(c)(4) nonprofit, which does not disclose its donors despite being largely dedicated to running television and web ads that promote right-wing causes and influence elections. The group is currently running pro-Romney ads [8] in Wisconsin, and spent [9] over $4 million in California in support of the anti-union Proposition 32 [10].

A large percentage of their 2010 funds came from a single source, the Center to Protect Patients' Rights [11] (CPPR), another 501(c)(4) which made massive donations in support of various conservative groups for the midterm elections. The Center gave AFF $12 million, about half of their total budget for that year. CPPR is run by Sean Noble, who Politico described [12] as an operative of the billionaire Koch brothers. Nobel was hired by the Kochs to coordinate with other conservative Super PACs to target Democratic representatives in 2010. One of Koch's subsidiaries, Georgia-Pacific, is a lead manufacturer of paper products in Wisconsin, including consumer tissue, towel and wiper products, corrugated packaging, and hardboard.