Submitted: The Two Sides Team September 3, 2012
The National Alliance of Forest Owners (NAFO) is urging the U.S. Environmental Protection Agencys (EPA) Scientific Advisory Board (SAB) to take a more simple and practical approach to the treatment of carbon dioxide (CO2) emissions regulations from wood biomass.
August 31 2012
National Alliance of Forest Owners, Washington, DC
The National Alliance of Forest Owners (NAFO) is urging the U.S. Environmental Protection Agencys (EPA) Scientific Advisory Board (SAB) to take a more simple and practical approach to the treatment of carbon dioxide (CO2) emissions regulations from wood biomass. The SAB will discuss during a teleconference today a final report provided by a panel that conducted a peer review of EPAsAccounting Framework for Biogenic CO2 Emissions from Stationary Sources.
The review panel proposes a hopelessly complicated path forward, said Dave Tenny, President and CEO of NAFO, who is speaking before the SAB today. Rather than accepting the recommendation, we are urging the SAB to sever the Gordian Knot and acknowledge to EPA that credible science, data and analysis show that biomass emissions are carbon neutral when the overall carbon in our forests is stable or increasing. By doing so the SAB can help EPA identify a more simple and practical way to account for biomass emissions.
In the 2010 Tailoring Rule, EPAfor the first timeregulated CO2 emissions from biomass energy in the same way as fossil fuel energy. As a result of NAFOs petition to EPA to reconsider this regulation, EPA deferred the regulation for three years (until 2014) while the agency studies the science and policy of regulating biomass emissions. This led to the SAB review process to advise EPA on the scientific and technical elements on which to base its policy choices. NAFO argued in its petition and to the SAB that biomass carbon emissions have traditionally been differentiated from fossil fuels because biomass energy is environmentally beneficial and does not increase the amount of carbon in the atmosphere.
NAFO notes that more than 100 notable scientists stated in a letter to Congress 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 that 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 is trying to reduce carbon in the atmosphere. We urge the agency to use the conclusions of noted science experts from across the country to establish a carbon accounting approach that supports this objective rather than one that defeats it, Tenny concluded.
NAFO provided its final written comments to the SAB August 24.
NAFO is an organization of private forest owners committed to advancing federal policies that promote the economic and environmental benefits of privately-owned forests at the national level. NAFO membership encompasses more than 80 million acres of private forestland in 47 states. Working forests in the U.S. support 2.5 million jobs. To see the full economic impact of Americas working forests, visit www.nafoalliance.org/economic-