Washington Post Slams Biomass Market Accusing EPA of Encouraging Deforestation
The EPA’s not-so-green emissions plan
By Washington Post Editorial Board
THE ENVIRONMENTAL Protection Agency is mandating cuts in the nation’s greenhouse gas emissions. But dozens of environmental scientists from Princeton to Baton Rouge to Berkeley warned last month that the way the agency is writing the rules threatens to sharply increase forest clearing, undermining the EPA effort. The culprit is a familiar obstacle to good policymaking in Washington: bioenergy.
The EPA program is supposed to force power generators to cut back on fossil fuel burning and increase electricity production from cleaner sources of energy. A crucial question, then, is how much credit to give to various alternative energy sources. Replacing coal with solar, wind, nuclear, geothermal and other low-emissions technologies eliminates practically all of coal’s massive carbon footprint, so energy companies that invest in those sources should get a lot of credit.
But the EPA is still figuring out how to count electricity produced by burning wood and other forest products in power plant boilers, an energy source euphemistically called “biomass.” At the moment the agency seems off-track. In a letter to the EPA, the scientists warned Administrator Gina McCarthy that the stakes are very high: Giving biomass too much credit would encourage a lot of wood burning. This is counterproductive, since live trees pull carbon dioxide out of the atmosphere. The scientists found that obtaining a mere 4 percent of the country’s electricity from wood — a realistic outcome if the rules aren’t well-written, according to the U.S. Energy Information Administration — would require burning 70 percent of today’s total timber harvest annually. Other timber would still be needed for construction and paper products.
It’s not enough to demand that landowners selling wood to power companies keep forests about the same as before, because sections of forest harvested for electricity production would have otherwise kept growing, sequestering more carbon dioxide as they grew. Replanting forests would help, but only after decades of regrowth, which is hardly a positive outcome. It’s also not enough to account for how bioenergy policy affects land use in one region or even one country; the EPA must also consider how using land to grow bioenergy products in one place affects how people use land for food, fuel and recreation elsewhere.
The scientists pointed out that Europe’s biomass industry has ramped up because of poor carbon accounting, with European power companies establishing wood pellet plants in the southeast United States and shipping the product across the Atlantic to be burned for electricity. The EPA, they said, is on the verge of making the same mistake. If the West settles on faulty accounting, other nations will burn their forests for electricity and claim credit for carbon dioxide cuts, too.
It might be that, absent an opportunity to sell timber for fuel, some landowners might uproot their forests and put the land to even less environmentally sound use. But the way to promote forest conservation is to give landowners who preserve their natural resources credit for doing so, not by pretending biomass is cleaner than it is.
Fortunately, the EPA has until the summer to get these rules right.
Washington Post Editorial: “The EPA’s not-so-green emission plan” Misses the Forest for the Trees
The editorial contends that EPA’s position on bioenergy and the use of wood pellets as a fuel source would result in the mass exploitation of our nation’s forests. To make that argument is truly missing the forest for the trees. The EPA laid out a pathway forward for addressing biogenic carbon emissions that was not prescriptive in nature and that develops a power plant rule to reduce carbon emissions while recognizing regional flexibility with regards to how these reductions would be met. To say that the EPA has encouraged the use of bioenergy and thus the increased harvest of forests is simply not true. To go further to state that the impending result would be the harvest of 70 percent of our forests is a drastic overreach.
The reality is quite the opposite. As reported in a recent U.S. Forest Service study of the effects of the bioenegy marketplace on the inventory of forests (US Effect of Policies on Pellet Production and Forests in the U.S. South, 2014), timberland area increases with an increase in demand for wood pellets as more plantations are established on marginal agricultural land.
Markets for forest products incentivize landowners to continue growing forests for their economic benefit. As a county, we benefit from all of the environmental services these forests provide. If we look at EPA’s framework the wrong way we put at risk the necessary incentives to sustain our forest and their owners for the next generation.
Forest Landowners Association
National Association of University Forest Resources Programs
Gina McCarthy, EPA Administrator
U.S. Environmental Protection Agency
William Jefferson Clinton Federal Building
‘1200 Pennsylvania Avenue, N.W.
Mail Code: 1101A
Washington, DC 20460
Dear Administrator. McCarthy,
On behalf of the NationalAssociation of University Forest Resources Programs representing 80 of the country’s universities that have programs devoted to forest resources and who share a common purpose to advance the health, productivity and sustainability of our nation’s forests, I am pleased to write you regarding your ongoing efforts on biomass carbon accounting.
As leaders in the science community, we appreciate your consistent emphasis on providing a strong science foundation for agency policy. We also acknowledge and wish to respond to your several requests for current, peer-reviewed science to inform the agency’s work.
To that end, we are providing the attached summary of science fundamentals, signed by 100 university experts in the field, that many in the science community, and the forestry disciplines in particular, strongly believe should underlie the agency’s policy considerations for biomass carbon accounting. These fundamentals, which are essential to understanding and benefitting from the low carbon attributes of managed forests and the biomass derived from them, are addressed in an article appearing in the November issue of the Journal of Forestry.
We appreciate the difficult task the agency faces as it tries to develop reasonable policies consistent with sound, relevant science. We recognize,’for example, that in the carbon accounting context the agency must rely on the expertise and judgment of policy makers to establish appropriate baselines, monitoring protocols and other implementation and compliance approaches that apply science in a relatively simple and cost effective way. We believe the fundamentals we provide can support a variety of policy approaches that meet programmatic requirements while addressing the practical needs of both the regulating and regulated community.
We invite the EPA to carefully consider these science fundamentals and look forward to lending our expertise to the agency as it further develops a sound, science-based accounting policy for biomass energy.
Science Fundamentals of Forest Biomass Carbon Accounting
Policy makers are increasingly considering the use of forest biomass energy to meet national, regional and state energy and carbon emissions objectives. As they do so, it is imperative that their policy decisions be informed by current peer-reviewed science on the carbon impacts of woody biomass as an energy source. Some studies on the subject offer views with stringent assumptions that may be confusing to decisionmakers.
Peer-reviewed literature examining the net emissions from the wide spectrum of forestbased activities reveals a number of important fundamentals policy makers should consider when characterizing the carbon impacts of the increased use of forest biomass for energy. While these fundamentals do not address all of the issues policy makers confront, they help clarify those most directly affecting the potential role forest biomass energy can play in energy and climate policy.
As experts in forest science, we recommend the following four science fundamentals to policy makers and others seeking to develop a science-based approach to biomass energy production.
Fundamental 1: The carbon benefits of sustainable forest biomass energy are well established.
The long-term benefits of forest biomass energy are well-established in science literature, As stated in the Fourth Assessment Report of the lntergovernmental Panel on Climate Change, “ln the long term, a sustainable forest management strategy aimed at maintaining or increasing forest carbon stocks, while producing an annual sustained yield of timber, fibre or energy from the forest, will generate the largest sustained mitigation benefit.2” Most debates regarding the carbon benefits of forest biomass energy are about the timing of the benefits rather than whether they exist.
Fundamental 2: Measuring the carbon benefits of forest biomass energy must consider cumulative carbon emissions over the long term.
The most effective carbon mitigation measures are those which reduce carbon accumulation in the atmosphere over time. Forest biomass energy yields significant net decreases in overall carbon accumulation in the atmosphere over time compared to fossil fuels. Comparisons between forest biomass emissions and fossil fuel emissions at the time of combustion and for short periods thereafterdo not account for long term carbon accumulation in the atmosphere and can significantly distort or ignore comparative carbon impacts over time.
Fundamental 3: An accurate comparison of forest biomass energy carbon impacts with those of other energy sources requires the use of consistent timeframes in the comparison.
The most common timeframe for measuring the impacts of greenhouse gases is 100 years, as illustrated by the widespread use of 10O-year global warming potentials.” This timeframe provides a more accurate accounting of cumulative emissions than shorter intervals. Measuring the net cumulative carbon emissions from forest biomass energy overa 100 yeartimeframe, as is done forfossil fuels, more accurately captures and more appropriately demonstrates the cumulative carbon benefits of biomass energy compared to fossil fuels.
Fundamental 4. Economic factors influence the carbon impacts of forest biomass energy.
Research demonstrates that demand for wood helps keep land in forest and incentivizes investments in new and more productive forests, all of which have significant carbon benefits. This is particularly true when landowner investments are made in anticipation of future market demand. Likewise wood markets significantly influence both the availability of wood and the kind of wood used for biomass energy. For example, large trees better suited for higher value markets are typically not used for energy. The consideration of landowner response to the marketplace is essential to fully accounting for the long-term carbon impacts of using forest biomass for energy.a Failing to consider the effects of markets and investment on carbon impacts can distort the characterization of carbon impacts from forest biomass energy.
Research on the use of forest biomass as an energy source to mitigate GHG emissions dates back to the late 1980’s. Changes in technology, forest conditions, and markets and global economics will influence forest biomass utilization now and in the future. A commitment to continuing research on forest biomass utilization is necessary to quantify the risks and benefits associated with its use, encourage dialogue and debate, drive innovation and investment in new technologies and inform policy.
December 4, 2014
On December 1, the Environmental and Energy Study Institute (EESI) submitted comments to the Environmental Protection Agency (EPA) on its Clean Power Plan, a draft regulation to cut carbon emissions from existing power plants. In November, EESI welcomed the EPA’s recent release of the Framework for Assessing Biogenic CO2 Emissions from Stationary Sources, which recognizes the important role that using “waste-derived feedstocks” as well as “forest-derived industrial by-products” can play in the low-carbon economy, as they “are likely to have minimal or no net atmospheric contributions of biogenic CO2 emissions, or even reduce such impacts, when compared with an alternate fate of disposal.” However, EESI cautioned that while the Framework is a step in the right direction, more needs to be done to achieve the significant greenhouse gas reductions that implementing the full suite of biomass energy sources would make possible. Unlike other renewable energy sources, waste materials can pose significant environmental problems if not sustainably dealt with – but if utilized they can provide significant benefits on several levels.
Biomass power can be derived from both waste (forestry, agriculture, organics, manure, landfills, waste water treatment) and purpose-grown biomass crops, such as perennial grasses. The Department of Energy’s 2011 Billion Ton Update estimates that there are currently 244 million dry tons of sustainably recoverable agricultural wastes in the United States, and that that number could reach as high as 910 million dry tons per year by 2030. The non-profit Dairy Checkoff estimates that U.S. farms alone could support 2,600 anaerobic digesters, producing 11.7 million megawatts of electricity per year. Already, biomass power generates enough energy to power 1 million homes and businesses, according to the Biomass Power Association. According to the Energy Information Administration (EIA), biomass power represents a full 22 percent of the United State’s renewable energy supply, and these resources must be adequately addressed by the proposed Clean Power Plan.
Not only does biomass provide a low-carbon source of consistent, baseload power, sustainable biomass can also provide significant economic and ecosystem co-benefits at the local level. For example, purpose-grown biomass crops can support a multi-functioning agricultural system by increasing a soil’s organic carbon, increasing its capacity to hold water and nutrients, and reducing runoff. Using organic wastes also monetizes a waste stream that would otherwise pose significant environmental problems to communities, yet these resources are consistently underutilized. Biomass power and waste-to-energy can provide local jobs, additional revenue to municipalities, and partially address the issues of overflowing landfills and growing waste streams.
EESI maintains, as do many forestry groups, scientists, and forestry product industries, that there is a fundamental difference between carbon emissions from burning fossil fuels and emissions from burning biomass that is sustainably harvested and regrown, and thus able to sequester carbon. Quantifying carbon emissions from woody fuels is important because individual states will need to assess whether their wood-based energy resources qualify under the Clean Power Plan. Therefore, EESI urges EPA and EPA’s Scientific Advisory Board to consider the significant body of peer-reviewed research that suggests that biomass power can help to reduce greenhouse gas emissions. Additionally, states such as Michigan and California have already created definitions for sustainable biomass energy. Both states draw a distinction for GHG emissions from wastes that would already be headed to the landfill, such as wood wastes and residues that have no value. EESI hopes that EPA will consider the types of standards already in place at the state level in their further clarification of the definition of ‘sustainable’ biomass.
Bioenergy can play a role in preserving and increasing the carbon stores of working lands. Using anaerobic digestion on farms to produce renewable natural gas creates valuable co-products (fertilizers, compost) that can be used to boost soil organic carbon levels and improve the health of soils. Additionally, bioenergy can help preserve rural land. The U.S. Geological Survey has found that urbanization in the Southeast could increase 190 percent by 2060, resulting in a 15 percent loss of agricultural land, a 10 percent loss of forests, and a 12 percent loss of grasslands, as well as negatively impacting wildlife, water and air quality. Providing an economic incentive to maintain farms and forested lands, as bioenergy and biofuels do, will help to preserve these lands. Preserving such open spaces is a critical component of climate adaptation, protecting critical wildlife habitats, and preserving air and water quality. All of this links back to the Clean Power Plan through recognition of the sustainable use of bioenergy.
Already, most states with a Renewable Portfolio Standard (RPS) recognize biomass energy, but it receives unequal treatment from both RPS and federal tax credits. To provide states flexibility in using their biomass resources, EESI recommends that EPA:
- Recognize that sustainable woody biomass harvesting (especially waste utilization) does not increase net carbon accumulation, as long as overall forest stocks are stable or increasing.
- Recognize thermal heat in the Clean Power Plan. Thermal energy represents 40 percent of energy used in the United States – its omission skews recognition of emissions from this use of energy.
- Build upon the programs and work occurring in the agriculture and forestry sectors at the state level, which have already defined and developed sustainable practices for biomass harvesting.
- The category of “waste-derived materials” should be inclusive of the significant organic waste streams created in the United States. The Clean Power Plan should incentivize the use of these organic wastes (including manure, landfill, organic, food waste) for the generation of electricity.
USFS January 30, 2015
Research Triangle Park, NC — A recently released study led by U.S. Forest Service scientists and published by the Forest Service’s Southern Research Station (SRS) finds that policies in the European Union (EU) and elsewhere requiring the use of renewable and low greenhouse gas-emitting energy are driving demand for wood pellets used to generate bioenergy. This demand could provide new markets for U.S. timber exports, increase wood prices, and lead to increases in forestland area.
Karen Abt, research economist with the SRS Forest Economics and Policy unit is the lead author of the report. “Southern forests and some northern forests as well, are being used to produce pellets for export to the EU,” she said. “Current and proposed production levels have the potential to increase prices, but may also lead to an increase in timberland area.”
Abt and her team used a computer model to simulate timber markets in the U.S. Coastal South through the year 2040. “We modeled a ‘business as usual’ scenario which continued the current level of wood production,” she said, “and an alternative scenario which increased the production of wood bioenergy.” This alternative scenario accounted for continued bioenergy demands based on the most recent projections of wood consumption by pellet mills and other bioenergy producers. These projections include all announced bioenergy wood demands, and while actual demands will likely be lower, there in considerable uncertainty in the bioenergy market.
In the “business as usual” baseline scenario, the simulation showed timber demand and prices rising in the short term, but falling in all areas across the South by 2040. However, when Abt’s team added the bioenergy component to the baseline, they saw a very different outcome. “Based on our assumptions, the results indicate increased bioenergy demand could result in an increase in pine non-sawtimber prices,” said Abt.
One might assume that increased demand for timber products and the associated boom in timber harvests would deplete southern forests. However, the study finds an increased demand for timber could mean just the opposite. In Abt’s simulations, the baseline scenario, which does not account for additional bioenergy demand, saw forested land decrease by 2040. But in the simulations accounting for additional bioenergy needs, there was actually an increase in the forest land base over the same period, despite the increased harvests.
As Abt points out, it’s all about supplying the increased demand. “We know people plant more when prices go up,” she said. “We also know that they keep more natural forest as forest when prices go up.”
Abt and her team based their initial research on EU policy, the Renewable Energy Directive, which requires a 20 percent contribution from bioenergy to the energy use of all EU Member States by 2020. However, it is now clear the EU requirements will extend even longer, which likely means an even greater impact.
“The EU has already extended their renewable requirement through 2030,” Abt said, adding that the new requirement also increases the amount of bioenergy required to 27 percent. “There is no indication that they will renege on this additional requirement, though the newest policy lacks country-specific requirements, which adds a bit of uncertainty.”
Abt points out that there is much that is still unknown about the interactions among policy, economics, and forestry. This makes projections such as these inherently uncertain.
“There are studies underway by the EU Environment Agency on the effects of the Renewable Energy Directive on the sustainability of southern forests,” Abt said. “If new requirements are adopted, this could affect use of southern forests for pellet production for export to the EU.” She adds, “All indications are that pellets from southern forests will meet the current EU requirements.”
The March 4 editorial titled “The EPA’s not-so-green emissions plan” is off track in suggesting that the Environmental Protection Agency “seems off track” in giving credit to wood bioenergy as an alternative energy source.
Trees are America’s greatest renewable resource and the forest products industry has long recycled wood waste from production processes to generate energy. Wood bioenergy is not new and is in fact a green energy success story that the United States can build on.
In conjecturing that EPA rules “threaten to sharply increase forest clearing”, the editorial ignores the realities of forestland ownership and forest protection in the United States. Most of the nation’s forests are owned by private landowners who value their forests for many reasons. Many will never clear their forests, while markets enable others to manage forest health threats, improve wildlife habitat, and keep forests as forests rather than selling them for permanent development.
The EPA is correct in recognizing the carbon benefits of wood and the potential of woody biomass to help meet the nation’s energy needs in an environmentally responsible manner.
National Association of State Foresters
444 N. Capitol St NW, Suite 540 | Washington DC, 20001
The Washington Post’s editorial on bioenergy got a lot wrong about biomass.
By the Biomass Power Association
Biomass power in the United States uses residues and byproducts. Period. There is no market to sell “timber for fuel.”
Loggers separate and sell their harvested fiber for the highest possible value for use in construction, furniture, or pulp and paper. The low-value tops, limbs and thinnings are sold to biomass power producers for a fraction of the other parts’ value. If there isn’t a biomass facility nearby, those materials are usually sent to landfills or burned openly.
There is near universal agreement on the carbon benefits of biomass power from sustainably sourced forest waste. The scientists whose letter to the E.P.A. was mentioned in the editorial endorsed biomass from wastes and residues as “truly low in carbon.”
What has been missing from this discussion is the acknowledgement that that is exactly what the U.S. biomass power industry is doing. It’s too easy to imply a looming forest crisis that doesn’t exist.
The E.P.A. made the correct decision to describe biomass from residues as a renewable, carbon-neutral energy source. Biomass is and will continue to be a crucial element to mitigate climate change.
President and CEO
Biomass Power Association
The Washington Post’s editorial about EPA’s position on wood bioenergy may have pleased a select number of “environmental scientists,” but it fundamentally misinforms the Post’s readers.
The editorial ignores that last fall 100 scientists from the nation’s pre-eminent forestry universities provided EPA with science fundamentals affirming the internationally acknowledged carbon benefits of bioenergy supported by exhaustive peer-reviewed research.
The Post also sets aside well-established science from the U.S. Forest Service and other scholars showing strong markets for forest products, including renewable energy, promote sustainable forests while reducing carbon accumulation in the atmosphere. These markets have helped increase standing timber in our forests by 50 percent in the last 50 years. EPA data show our forests remove 15 percent of industrial CO2 emissions from the atmosphere each year.
Finally, the editors omit that unlike fossil fuels (which permanently deposit additional carbon into the atmosphere), biomass from low grade wood recycles carbon emissions through growing trees. High value wood from large, high quality trees (which is not used for bioenergy) is used for homes, furniture and flooring products that store carbon for decades.
EPA correctly recognizes the scientifically proven carbon benefits of wood and correctly includes wood bioenergy as a solution for reducing carbon in the air.
Dave Tenny, President and CEO, National Alliance of Forest Owners
122 C Street, NW, #630
Washington, DC 20001
202-747-0739 (office) or 202-964-7519 (cell)
M. Seth Ginther, Executive Director, US Industrial Pellet Association
2100 East Cary Street, 4th Floor
Richmond, VA 23223