NAFO urges EPA to keep biomass rules simple

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
per cent 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 per cent 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.