National Alliance of Forest Owners supports U.S. EPA's proposed rule to defer regulation of biomass carbon emissions for three years, states policy development guides for renewable biomass energy
April 5, 2011
– David P. Tenny, President and CEO of the National Alliance of Forest Owners (NAFO), testified today in support of EPA's proposed rule to defer regulation of biomass carbon emissions for three years and urged the agency to act promptly to fully recognize biomass carbon benefits in its forthcoming science and policy review to bring the agency in line with Administration policy. Tenny delivered his remarks at the EPA's public hearing in Washington, DC.
Tenny said, "President Obama has stated that biomass energy is an important part of his renewable energy agenda. EPA must act decisively and quickly to come into alignment with this policy direction." Tenny reminded EPA that NAFO, "stands ready to work with the Agency to establish a policy recognizing the full carbon benefits of forest biomass as an energy source," and made the following points to guide policy development for renewable biomass energy:
Forest carbon accounting systems are policy determinations, not scientific conclusions, and should be used to achieve practical policy outcomes.
The EPA should measure forest carbon change at the national scale. The forest carbon cycle is dynamic, global, and ongoing. Restricting forest carbon accounting to local areas or specific timeframes places arbitrary limits on forest carbon that distort the forest carbon picture.
The EPA must recognize the prevailing scientific conclusion that the forest carbon cycle is continuous and has no "beginning." The "carbon debt" model of carbon accounting is arbitrary on its face for two reasons – it ignores the carbon removed from the atmosphere prior to harvest, and it ignores that the harvested stand is merely one small part of the total forested landscape that removes carbon from the atmosphere before, during, and after the time of harvest.
The EPA must avoid establishing arbitrary baselines, such as "business as usual," to account for carbon emissions from biomass. Current forest practices yield significant carbon benefits that private forest owners provide without compensation. A "business as usual" baseline would arbitrarily "take" these benefits and introduce additional costs to forest management. Rather than promoting forest conservation, the loss in value of forest land would create additional economic incentive to convert forests to other uses.
The EPA must recognize that all parts of the tree are part of the same carbon cycle, so net forest carbon flux should be measured across the forest, not for specific product streams. Separate carbon measurements for different feedstocks will yield arbitrary results that confuse rather than clarify the nature of the forest carbon cycle. While an important market, biomass energy produces some of the lowest returns in the forest products value chain. Consequently,there is little risk that forest owners will divert trees used for building materials and other high value products to low value biomass.
Mr. Tenny's prepared remarks are available on request.
For more information, including NAFO's extensive response to EPA's Call for Information, the economic impact of the Tailoring Rule's treatment of biomass energy, and a scientific white paper on the unintended consequences of regulating biomass the same as fossil fuels, please visit www.renewablebiomass.org.
NAFO is an organization of private forest owners committed to advancing federal policies that promote the economic and environmental values of privately-owned forests at the national level. NAFO membership encompasses more than 79 million acres of private forestland in 47 states. Private, working forests in the U.S. support 2.5 million jobs. View NAFO's interactive map to see the economic impact of America's working forests.