EPA agrees biomass reduces carbon emissions

The U.S. Environmental Protection Agency (EPA) has issued a draft policy recognizing that forest biomass can help reduce carbon emissions, the Arkansas Forestry Association reported in a November statement. "For years, AFA has been involved in state and national coalitions that have worked to promote the forestry community as a part of the sustainable solution to our nation's energy needs and environmental health as well as develop new markets," AFA said.

According to AFA Executive Vice President Max Braswell, the Arkansas Department of Environmental Quality and Arkansas Public Service Commission included in their comments to the EPA that the "Proposed Rule should be clarified and changed in various ways to better enable compliance, particularly for states that can reasonably be expected to rely on net imports from renewable energy generators for some or all of their renewable electricity generation."

Following are statements and analysis from several national advocacy groups:

American Forest and Paper Association

The Environmental Protection Agency (EPA) released its revised Accounting Framework for Biogenic CO2 Emissions From Stationary Sources (Accounting Framework) and accompanying memorandum to EPA's Regional Air Division Directors from Acting Assistant Administrator Janet McCabe. The memorandum addresses how to account for biogenic carbon emissions from stationary sources under the Clean Air Act Section 111(d) greenhouse gas (GHG) rule for existing electric utilities and the Prevention of Significant Deterioration (PSD) permitting program.

AF&PA's preliminary and cursory look at the memorandum and Accounting Framework indicates EPA recognizes that:
* bioenergy from forest-derived industrial by-products such as black liquor or residuals with no other current market uses, have minimal or no net atmospheric contribution of CO2 emissions or even reduce such impacts when compared to their alternative fate;
* certain waste-derived feedstocks such as municipal solid waste (e.g. urban wood waste, yard trimmings) and wastewater have minimal or no net atmospheric contribution of CO2 emissions;
and * bioenergy from forest-derived industrial by-products, waste-derived feedstocks, and "sustainably-derived" forest-derived feedstocks may be considered an approvable plan element in state implementation plans for EPA's 111(d) rule for existing electric utilities.

In addition, EPA plans to propose revisions to the PSD rules that will exempt from the Best Available Control Technology (BACT) requirement GHG emissions from waste-derived feedstocks and from non-waste biogenic feedstocks derived from sustainable forestry practices. For non-waste biogenic feedstocks to be exempt from BACT requirements, EPA plans to allow permit applicants to demonstrate that these feedstocks come from sustainably managed lands. EPA plans to issue additional PSD BACT guidance related to biomass feedstocks.

EPA has requested that its Science Advisory Board (SAB) conduct a targeted review of specific elements of the revised Accounting Framework. EPA also requests that the SAB reconvene the members of the original Biogenic Carbon Emissions Panel to conduct this review. The SAB review will include an opportunity for public comment.

Forest Resources Association

Preliminary review indicates that EPA has heard and understood comments and arguments from forest industries and other forest users, urging recognition of biogenic sources', particularly forests', capacity to reabsorb and store carbon in a way to offer significant support to the Administration's greenhouse gas management goals.

More detailed study and consultation on the Framework will be necessary to determine what kind of obstacles remain in assuring development of a practical policy that can co-exist with forest product manufacturing.

National Alliance of Forest Owners

The U.S. Environmental Protection Agency (EPA) released a revised draft carbon accounting framework for biogenic CO2 emissions along with a memo to EPA Air Division Directors nationwide detailing its biomass policy for the proposed Clean Power Plan and Prevention of Significant Deterioration program. NAFO President and CEO Dave Tenny released the following statement in response.

"We are pleased that EPA is acknowledging that biomass is part of our nation's climate and energy solution. This aligns EPA with the White House and USDA in recognizing the significant long-term carbon benefits that biomass provides. EPA has clearly signaled an intent to recognize the carbon benefits of biomass in forthcoming rulemakings.

EPA can only accomplish this through practical approaches that work in the real world. Simplicity is the key. We look forward to working with EPA to develop final policies capturing the full carbon benefits of biomass and working forests nationwide."

Amwerican Forest FOundation/American Tree Farm System

Yesterday, the U.S. Environmental Protection Agency (EPA) issued a long-awaited policy saying they believe forest biomass that is a residue or waste from forestry activities (i.e. mill waste), a municipal waste, or comes from sustainable forests, can help reduce carbon emissions. While there are a number of uncertainties and outstanding questions with this policy, including how "sustainable forests" will be defined, we believe this is a positive step forward for family forest owners!

We also believe there is an important role for the American Tree Farm System, as an internationally recognized, third-party audited forest certification system, in demonstrating sustainable forests. We will be working with EPA, state governments, and our partners to make this case, and the case for all the various mechanisms for demonstrating sustainable forests and hope you'll join us in these efforts.

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