Artificial Mandates Should Not Keep EPA From Declaring Biomass Carbon Neutral

The manufacturing industry, and wood products manufacturers in particular, are awaiting an accounting framework from the Environmental Protection Agency (EPA) to clarify how biomass carbon emissions will be treated in air regulations. EPA has been working on this framework for over three years. Unfortunately, until the framework is issued, biogenic carbon emissions will be regarded as the same as fossil fuel emissions.

Sustainably-managed biomass was treated as carbon neutral for years, but EPA issued its Greenhouse Gas (GHG) Tailoring Rule in 2010 which, for the first time, did not distinguish between carbon emissions from biogenic and fossil fuels. Although EPA quickly issued a Deferral Rule to hold this determination about biogenic fuels in abeyance for three years, the U.S. Circuit Court for the District of Columbia ruled EPA did not have the authority to defer regulation of any carbon dioxide (CO2) emissions. Further, last month the U.S. Supreme Court partially overturned the Tailoring Rule and EPA’s authority to regulate GHG emissions under the Clean Air Act’s permitting program. But, with the deferral having been vacated, the framework is needed more than ever to differentiate biomass emissions as unique and carbon neutral for EPA’s many other existing and proposed air regulations.

We learn in biology classes that trees absorb CO2, a principal greenhouse gas, as they grow. This removes it from the atmosphere and releases oxygen in its place. This CO2 is sequestered during the life of the tree and beyond, in one of the many products made from trees. Trees complete their carbon cycle when they die, decay or combust, releasing their absorbed and sequestered CO2. This carbon, stored as biomass in trees, will eventually be returned to the atmosphere – whether it is burned for energy or allowed to biodegrade – but sustainably-managed forests will continue to absorb CO2. When coupled with long-term carbon storage in wood products, the forest-to-products cycle remains a net carbon sink.

Wood products facilities use all parts of the raw material, not only in the manufacturing of products such as lumber, plywood, OSB or engineered products, but also to create the energy needed to do so. On average, almost 80 percent of the energy American Wood Council member facilities generate comes from biomass manufacturing residuals. The forest products industry has created a highly efficient system of using bioenergy for power, which further reduces reliance on fossil fuels. Similarly, greenhouse gases are reduced further when wood products are used instead of other materials that are much more fossil-fuel dependent in their production. Use of our biomass residuals and our commitment to forest planting has produced a sustainable industry which has seen net increases in forest stocks over the last 50 years.

Around the world, the carbon neutrality of biomass from wood manufacturing has been recognized repeatedly by studies, agencies and legislation, including guidance from the U.N. Intergovernmental Panel on Climate Change (IPCC). The IPCC has explicitly stated that “wood products can displace more fossil-fuel intensive construction materials such as concrete, steel, aluminum and plastics, which can result in significant emission reductions.”

Public policies should not construct artificial mandates that disrupt our nation’s existing, efficient and balanced biomass system. Rather, EPA should rely on good science to create a simple and workable framework. Biomass emissions are carbon neutral and should be excluded from GHG emission regulations.

We look forward to EPA’s release of the long-awaited and revised “Accounting Framework for Biogenic CO2 Emissions from Stationary Sources” and its formal recognition that sustainably-managed forests and forest products sequester carbon, reduce the nation’s GHG emissions and that use of biomass for energy is carbon neutral.

Robert Glowinski is president of the American Wood Council (AWC). AWC is the voice of North American traditional and engineered wood products, representing approximately 75 percent of the industry. From a renewable resource that absorbs and sequesters carbon, the wood products industry makes products that are essential to everyday life and employs 360,000 men and women in well-paying jobs.