Source – The National Alliance of Forest Owners
The National Alliance of Forest Owners (NAFO) told the U.S. Environmental Protection Agency (EPA) today that they support the proposed rule to defer the regulation of greenhouse gas (GHG) emissions from biomass for three years while the agency studies the science and policy of regulating biomass energy the same as fossil fuels. NAFO urged the EPA to ensure the rule will not automatically sunset in three years if EPA takes no further action – predicting the workload of the agency could delay a decision beyond three years.
David P. Tenny, President and CEO of NAFO, underscored the importance of taking this time to conduct an independent, comprehensive review of the science and policy, “This week, Massachusetts issued proposed regulations that effectively shut the door on renewable biomass energy in that state. This appears to be what officials wanted when they initiated a study on biomass energy that limited the area and timeframe considered in a way that significantly skewed the outcome. The flawed study resulted in a flawed policy. EPA can learn from the unfortunate outcome in Massachusetts to put in place an even-handed review.”
Tenny noted that EPA’s review is more a question of policy than science, “The science is really a settled question – the cycle of biogenic carbon is biology 101. Carbon released from biomass energy is replaced in real time through continued forest growth without increasing overall carbon in the atmosphere. The question EPA must answer is how policy can best apply this science to meet our renewable energy needs and reduce unrecyclable fossil fuel carbon emissions. Unlike Massachusetts, we are hopeful that EPA will conduct a review of policy options free of arbitrary assumptions or parameters that skew well settled science.”
NAFO’s comments to the EPA provide answers with supporting science to the policy questions EPA must answer:
- Forest carbon is most accurately measured on a national scale over a continuous timeframe rather than applying arbitrary time and space limitations on carbon measurement
- Because forests remove more carbon from the atmosphere than they release through natural and human activities, biomass energy emissions don’t increase carbon in the atmosphere and should be excluded from GHG regulations for stationary sources
- EPA should not impose a regulatory “baseline” or “business-as-usual” requirement on forest carbon that would compel forest owners to continually increase the carbon stored in individual forest tracts.
Tenny reminded the EPA that NAFO, “stands ready to work with the Agency to establish a policy recognizing the full carbon and landscape benefits of forest biomass as an energy source.”
NAFO’s comments were submitted as part of the public comments for the proposed rule entitled, “Deferral for CO2 emissions from Bioenergy and Other Biogenic Sources under the Prevention of Significant Deterioration and Title V Programs.”
It’s really quite simple. GHG emissions was not an issue during pre-Industrial times because the carbon cycle – which includes plowing and tilling of land – was closed loop. The advent of the Industrial Age was characterized by the need for denser fuels. These were found in subterranean geologic formations in the form of fossil fuels (carbon sequestered as coal and oil). The carbon cycle was violated (open looped) with carbon that had been sequestered for millions of years.
Carbon accounting that measures biogenic emissions and compares it with fossil atmospheric impacts is like comparing the arrangement of deck chairs to the fatal impact of the iceberg on the Titanic! Fossil carbon is carbon positive and a climate threat. Biogenic sources are carbon neutral and should be exempt from EPA comparative accounting.