25x’25

The 25x’25 Alliance commends the more than 100 scientific and academic leaders and experts who signed on to a letter to key members of the Senate this week sharing their concerns over EPA’s handling of “biogenic” carbon emissions and the consequences the agency’s actions could have on the development of biomass energy facilities.  The letter makes a detailed and articulate case against an emissions regulatory “tailoring” rule finalized by EPA in June that treats wood-burning emissions the same as fossil-fuel emissions. The authors say treating biomass the same as fossil fuels could not only stop the development of new emission reducing biomass energy facilities, but  could also encourage existing biomass energy facilities to convert to fossil fuels or cease producing renewable energy.

The letter lays out the basic and unalterable fact 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. In contrast, carbon dioxide released from fossil fuels increases the amount of carbon in the cycle.

The EPA rule is designed to “tailor” permitting programs to limit the number of facilities that would be required to obtain new operating permits based on their greenhouse gas emissions. The rule appears to ignore the agency’s own precedent and the internationally recognized carbon neutrality of biomass. The EPA insists that it has not reversed its position, but the agency last week announced its plans to conduct a 60-day public comment period seeking more information on how climate regulations should treat greenhouse gas emissions from biomass combustion.

Many in the biomass industry fear that EPA could ultimately decide energy from biomass is not carbon neutral and impose penalties on the emissions from biomass facilities. The increased costs, the industry says, would eliminate profits, killing the industry in its relative infancy. Last month, a congressional delegation of more than 60 members wrote to EPA demanding that biomass be kept carbon neutral because of its role as a renewable source of energy that creates jobs and helps pay for projects that thin forests.

There are vast differences in the source of biogenic and fossil carbon dioxide. Burning fossil fuels that are mined from millennia-old deposits of carbon produces an addition to carbon in the atmosphere. On the other hand, burning woody biomass recycles renewable plant growth in a sustainable carbon equilibrium producing carbon neutral energy. Also, biomass power facilities generally contribute to a reduction of greenhouse gases because the use of forest fuels in a modern boiler also eliminates the emissions of methane, a GHG that is 25 times more powerful than carbon dioxide, which would otherwise occur from open burning, land filling or decomposition. In contrast, the mining of coal and exploration for oil and gas release significant amounts of methane and other harmful pollutants into the environment.

Any modeling to examine the impact of carbon-based fuel sources must account for all impacts. Regulators should not have to be reminded that fossil fuels produce a variety of greenhouse gases and pollutants with more negative environmental impacts than woody biomass. The rule, as written, undermines the Obama administration’s support for renewable energy policy in this country. Properly managed forestlands and sustainably produced woody biomass are key components of a strategy that will reduce the nation’s dependence on fossil fuels and lead the United States to a new, clean energy future.

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