Submitted: The Two Sides Team June 7, 2013

The Environmental Protection Agency (EPA) is expected to soon propose changes to its 2010 greenhouse gas regulations (commonly referred to as the “Tailoring Rule”) to address the unique carbon characteristics of renewable forest bioenergy. These amendments will significantly shape how privately owned working forests fit into overall U.S. climate change policy.

EPA deferred regulating carbon emissions from forest bioenergy under the Tailoring Rule for a three-year period while it studies the science because, unlike fossil fuels, forest bioenergy recycles atmospheric carbon.
National
Association of Forest Owners – June 4, 2013

The Environmental Protection Agency (EPA) is expected to soon propose changes to its 2010 greenhouse gas regulations (commonly referred to as the “Tailoring Rule”) to address the unique carbon characteristics of renewable forest bioenergy.  These amendments will significantly
shape how privately owned working forests fit into overall U.S. climate change policy.

EPA deferred regulating carbon emissions from forest bioenergy under the Tailoring Rule for a three-year period while it studies the science because, unlike fossil fuels, forest bioenergy recycles atmospheric carbon.

When wood from a mill or forestry operation is used for energy, the carbon released is carbon that was recently absorbed from the atmosphere by growing trees.  That is why the international norm has been to recognize that energy from wood doesn’t increase the net amount of carbon circulating in and out of the atmosphere, particularly in places like the U.S. where annual tree growth far exceeds harvest.

Each year the net annual growth in U.S. forests, taking into account all harvests used for a vast array of goods and services, including bioenergy, is enough to offset more than 14% of our annual carbon emissions.  For the most part forest owners provide this climate change mitigation to the public free of charge.  Many view it as a key contribution to the climate change solution.  However, the Tailoring Rule amendments will heavily influence the extent to which private forest owners, who own and manage nearly 60% of the forests in our country, will continue providing this benefit.

For example, amendments that are so complicated and costly to administer that forest bioenergy becomes economically infeasible would foreclose forest biomass as a viable alternative to fossil fuels and could prevent forest owners from eventually using accumulated forest carbon as an effective carbon mitigation tool in the energy sector.

This lost opportunity could reduce investments in forest management; decrease overall forest value, including the value of the accumulating carbon; and increase pressure to convert privately owned forests to other less carbon-friendly land uses that could provide a greater economic return to the landowner.

The prudent course for EPA to take, and one with real potential for climate change mitigation, is to pursue amendments to the Tailoring Rule that incorporate the carbon benefits of forest bioenergy in the broadest and simplest terms (for example, recognizing that carbon emissions from bioenergy don’t increase carbon in the atmosphere and, therefore, shouldn’t trigger regulation so long as overall carbon is increasing in our forests).  EPA could then work with the U.S. Department of Agriculture and other federal agencies to constructively engage forest owners on policies that promote the considerable mitigation benefits private forests provide.  Such an approach, rooted in the premise that the long-term carbon benefits of maintaining working forests far outweigh the temporary effects of a narrow, ill-fitting regulatory approach, would send a strong signal to forest owners that they remain part of the climate change solution.

Forest owners are prepared to help.  Getting the Tailoring Rule amendments right will help make sure they can.

Dave Tenny, NAFO President and CEO

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