Specifically urging the U. S Environmental Protection Agency (EPA) to amend the greenhouse gas Tailoring Rule to fully recognize the carbon benefits of forest bioenergy.
Forest bioenergy is a renewable, low carbon part of our country’s long term energy solution.
- Forest bioenergy accounts for 8% of renewable electricity production.
- Forests throughout the country reabsorb carbon dioxide in a continuous, natural cycle. When forest bioenergy is used, it releases into the atmosphere carbon dioxide that was captured in recent years.
- The U.S. grows more trees than it harvests. The U.S. Department of Agriculture (USDA) reports that the standing inventory (volume of growing trees) in U.S. forests has grown by 50% between 1953 and 2011.
- The EPA reports that carbon storage in U.S. forests continues to increase, capturing more than 900 million metric tons of carbon dioxide equivalents annually and offsetting 12% of U.S. CO2 emissions.
The carbon benefits of forest bioenergy are well established and scientifically supported.
More than 100 notable scientists have written to Congress urging the appropriate treatment of forest bioenergy carbon in national energy policy, stating that:
- “…the carbon dioxide released from the combustion or decay of woody biomass is part of the global cycle of biogenic carbon and does not increase the amount of carbon in circulation…” and;
- “…the regeneration of the forest [where] the volume of removals [is] no greater than new growth less mortality results in stable levels of carbon in the forest and sustainable removals as a carbon neutral source for energy.”
EPA’s policy on forest bioenergy carbon emissions must be timely, practical and cost effective, and must support rather than discourage the use of forest bioenergy as part of a diversified energy portfolio.
- The Court of Appeals for the District of Columbia has vacated EPA’s 2011 Deferral Rule. Unless EPA acts immediately to amend the Tailoring Rule, forest bioenergy will be regulated the same as fossil fuels
- EPA’s Science Advisory Board (SAB) recommendations for forest bioenergy carbon accounting are complex, speculative and costly. The SAB would:
- Estimate future carbon impacts using highly subjective assumptions and complex computer modeling to project market demands and landowner reactions decades into the future.
- Jeopardize the recognition of ongoing voluntary carbon accumulations in private forests as an offset to carbon emissions from forest bioenergy.
- Allow for carbon accounting based on the harvest of small forested areas over short timeframes, which can significantly distort carbon impacts.
An overly complex policy will increase cost and uncertainty, discourage the use of forest bioenergy in the marketplace and hasten the loss of private forests, thereby reducing forest carbon stocks.
- Forest bioenergy is a low-margin energy source. Policies that increase the complexity and cost of forest bioenergy use will make it uneconomic in the marketplace.
- Discouraging markets for forest bioenergy reduces the value of private forests and hastens their conversion to non-forest uses.
EPA’s amendments to the Tailoring Rule should regulate forest bioenergy carbon emissions only if data show that forest carbon stocks at the national level are not stable or increasing.
- EPA has the authority to develop a practical and simple policy using regularly collected USDA data to identify the carbon impacts of forest bioenergy. This approach would be more reliable than estimates using uncertain assumptions and overly complex modeling.
- EPA’s policy should reaffirm the scientifically sound and internationally accepted policy that forest bioenergy will not increase carbon in the atmosphere so long as overall forest carbon stocks at the national level remain stable or are increasing.
- EPA should ensure that agencies with specific science and policy expertise, such as USDA and DOE, are directly involved in policy making.
- 74 Fed. Reg. 55292 (October 27, 2009).
- 75 Fed. Reg. 31514 (June 3, 2010).
- U. S. Environmental Protection Agency Combined Heat and Power Partnership. Biomass Combined Heat and Power Catalog of Technologies, 96 (September 2007).
- U.S. Energy Information Administration, Monthly Energy Review.
- USDA Forest Service 2010 Resources Planning Act Assessment (August 2012).
- Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990 – 2011, U.S. Environmental Protection Agency (April 15, 2013).