EPA's Policy Direction on Biomass Carbon Emissions is a Step in the Right Direction but Uncertainty Remains

The EPA has taken a step in the right direction, but it is not a win for forestry yet.  The new draft accounting framework and guidance memo released shows EPA recognizes the overall sustainability without additional regulations.  EPA is confirming what we already knew and have been telling them all along.  Wood is a renewable resource and is sustainable.

On November 19 the Environmental Protection Agency (EPA) announced its path forward on biomass carbon accounting.  Overall, the EPA actions are positive step in the right direction, but uncertainty remains.


The agency released two documents:

    • A Memorandum to regional offices outlining how the agency will approach biomass in its proposed Power Plant Rule(111(d)) and in forthcoming revisions to the Tailoring Rule.


    • A revised draft of the carbon accounting framework for biogenic CO2 emissions, which will be subject to further public notice and comment through EPA's Science Advisory Board.


EPA's Memorandum delivers a positive signal that the agency intends to recognize the carbon benefits of biomass in its forthcoming rulemakings by:

    • Stating EPA's expectation that many states can and should rely on biomass from sustainable forests to meet carbon reduction targets under the Power Plant Rule (111(d)).  


    • Stating the agency's intent to propose that biomass from sustainable forests should be exempted from Best Available Control Technology (BACT) in forthcoming amendments to the Tailoring Rule. 


The Framework has been reconstituted in a way that appears to be much less prescriptive and much more flexible to a variety of policy approaches. 

    • EPA makes it clear that the framework is a policy resource rather than a policy driver and that it will continue to evolve over time.  The framework will inform agency policy along with other sources of information.


    • The Framework continues to lack the simple approach to implementation that members of Congress have repeatedly urged.  


    • The Framework maintains the use of complex algebraic formulas tied to specific inputs. 


EPA's memorandum states that the agency will consider biomass from "sustainably managed lands" and "sustainable practices" as carbon neutral.   EPA does not define "sustainable" but implies the term will be used in forthcoming policy. Any reference to "sustainability" in future policy should:

    • Be clear, practical and simple and encourage rather than discourage the use of biomass.  


    • Focus on carbon only and recognize that biomass is sustainable so long as overall forest carbon is stable or increasing.


    • Recognize that even when overall forest carbon is not increasing, mill and harvest residuals and material removed from the forest through forest thinning will have a minimal impact on overall carbon in the atmosphere.


“The new draft accounting framework and guidance memo released by the EPA today are important steps toward providing greater clarity to our mills that have invested in biomass boilers, and to our forestland owners who are providing a sustainable source of energy.  We can help rural economies and help address climate change by making good use of the biomass in our forests.” Senator Jeff Merkley (D-Oregon)