EPA tries to straddle split between forest owners and green groups over burning wood

Elizabeth Harball
December 3, 2014
E&E Climate Wire

If a tree falls in the forest, does burning it for energy help fight climate change? Or does it heat the planet even faster than burning fossil fuels?

Conflict and confusion surrounding this quandary emerged in a series of comments submitted this week to U.S. EPA about the potential use of wood-based energy under the Obama administration’s plan to reduce greenhouse gas emissions in America’s power sector. How the agency ultimately addresses the issue is likely to alter the future of America’s forests and their role in mitigating climate change.

In the comments, industry and environmental groups formed familiar battle lines over biomass energy, arguments already heard in some of the highest U.S. courts and repeatedly analyzed by top scientists and think tanks. Industry groups such as the American Wood Council believe that burning wood for electricity is carbon-neutral, simply harnessing energy from within a natural cycle in which trees take in carbon dioxide during their life span and then releasing it again when they die.

“… EPA should allow states to consider the use of biomass-derived fuel in effected units as an emission reduction measure,” the American Forest & Paper Association and the American Wood Council wrote in comments submitted this week. “In order to do so, EPA must distinguish biogenic CO2 emissions from fossil fuel CO2 emissions and provide a clearer policy that recognizes the carbon neutrality and [greenhouse gas] reduction benefits from biomass energy.”

But because wood-fired power plants put out greenhouse gases just like fossil fuel-powered plants, a number of environmental groups staunchly oppose the technology, retorting that it takes far too long for trees to grow back and reabsorb the produced emissions.

“As compared to coal and natural gas-based electricity generation, burning solid biomass always emits more carbon pollution per megawatt-hour of electricity generated and can result in higher net greenhouse gas emissions for decades,” a coalition of environmental nongovernmental organizations including the Natural Resources Defense Council, the Partnership for Policy Integrity and the Clean Air Task Force wrote in their comment letter.

“EPA’s targets will be stronger if they explicitly exclude new biomass,” they added.

EPA grapples with ‘space and time’

Pacific Forest Trust President Laurie Wayburn, whose organization represents private forest owners, called EPA’s task in sorting out the biomass debate “a tough one because they’ve got to get the metrics right.”

“Energy’s one of those things where space and time really matter,” Wayburn added. “Biogenic energy from forests and offsets from forests only true up over time. We’re used to that one-way street, CO2 goes out. … All of a sudden, we’re saying, ‘Oh, but it’s going to come back in.'”

EPA has so far only hinted at where it will ultimately fall in this debate. In the agency’s proposed rule for power-sector carbon emissions, it states, “Broadly speaking, burning biomass-derived fuels for energy recovery can yield climate benefits as compared to burning conventional fossil fuels.”

And in a controversial memo sent out last month, Janet McCabe, EPA’s acting assistant administrator for the Office of Air and Radiation, wrote, “Use of waste-derived feedstocks and certain forest-derived industrial byproducts 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” (ClimateWire, Nov. 20).

But in a proposed “accounting framework” issued in tandem with the memo, a document outlining a scientific assessment on how to calculate emissions from biomass energy, EPA also seemed to acknowledge the importance of the time lag between burning of wood-based energy and tree regrowth.

“The potential mismatch of temporal scales between direct emissions coming out of the stack when a biogenic feedstock is used and longer term factors, including carbon sequestration via feedstock growth or carbon accumulation in soil, adds to the complexity of biogenic CO2 assessments,” it stated.

Warring factions demand certainty from EPA

Comments submitted this week show that despite the recently released memo and accounting framework, both the forestry sector and environmentalists remain unsure of how EPA will ultimately regulate emissions produced by wood-fueled power.

In its comment letter, the National Alliance of Forest Owners praised McCabe’s memo but added, “If EPA proceeds to finalize a rulemaking for existing fossil fuel-fired EGUs [electric utility generating units] under Section 111(d), it must clarify that biomass energy facilities will not be considered affected EGUs that must be regulated by the states.”

The American Forest & Paper Association and the American Wood Council agreed, stating that “significant uncertainty remains” about EPA’s treatment of biomass emissions under the Clean Power Plan.

It continued, “With the lack of clarity and such a short time period for evaluation of the new materials, we remain concerned that EPA could — in forthcoming guidance, rule language or in reviewing states’ implementation plans — fail to adequately resolve regulatory uncertainty. This could have the unfortunate result of continuing to dissuade the use of beneficial biomass energy.”

Environmental organizations also expressed dissatisfaction with the accounting framework, which was widely anticipated as the document that would provide clarity on the agency’s stance on the biomass emissions ahead of the close of the Clean Power Plan comment period.

The letter from the coalition, including the Clean Air Task Force, the Sierra Club and the Natural Resources Defense Council, said the accounting framework “provides little in the way of specific direction,” adding, “In most instances, the revised Framework catalogs the various options for analyzing biogenic emissions … but fails to signal a preference for one approach or another.”

As of 2013, biomass power only accounted for 1.48 percent of total U.S. electricity generation, according to the U.S. Energy Information Administration. But as states begin to consider how they might comply with the upcoming regulations and how wood-fueled power might fit into their plans, both sides called for EPA to take a solid stand on biomass soon.

“We’re at a point where EPA needs to make decisions,” said Jonathan Lewis, senior counsel for climate policy with the Clean Air Task Force. “The rubber is hitting the road here, and we all need a sense of how EPA is going to consider biomass emissions.”

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