Will Biogenic Emission Regulation Curb Biomass Growth?

According to the National Alliance of Forest Owners (NAFO), the inclusion of biomass emissions (biogenic carbon emissions) in the EPA’s Clean Air Act greenhouse gas permitting program hinders growth of renewable energy. However, the Environmental Defense Fund (EDF) is countering their argument saying that there is public data on investments in biomass showing that it is in fact growing. The irony is that both groups cite the same study from Forisk Consulting to support their claims although the study was in fact funded by NAFO.

In December 2010, Forisk Consulting released a study titled, “Economic and Regional Impact Analysis of the Treatment of Biomass Energy Under the EPA Greenhouse Gas Tailoring Rule.” According to NAFO, the study found that the U.S. Environmental Protection Agency’s (EPA) Greenhouse Gas Tailoring Rule’s current treatment of biomass energy emissions will put over 130 renewable energy projects “at risk” for cancellation or delays.

“The Tailoring Rule is a powerful deterrent to forest biomass energy investments and job opportunities,” NAFO President and CEO David P. Tenny said of the study’s findings. “We’re already seeing the economic impact of the Tailoring Rule, as renewable energy projects are delayed or stopped altogether due to regulatory uncertainty. Left unchanged, the Tailoring Rule threatens the long-term viability of the biomass energy sector which, in turn, undermines the renewable energy goals of the Administration and Congress.”

Back in September, the Environmental Protection Agency (EPA) announced that it was considering equating biogenic carbon emissions with fossil fuel emissions under the Tailoring Rule, which requires the accounting and reporting of greenhouse gas emissions under the Renewable Fuels Standard (RFS2). Biogenic carbon emissions are those that are naturally created during the combustion and decay of woody biomass. In the past, the EPA has always considered them carbon neutral.

However, according to EDF calculations, existing and announced wood bioenergy projects increased during the past year by nearly 35 percent–from 112 projects to 151 projects–across 11 southern states alone: Alabama, Arkansas, Florida, Georgia, Louisiana, Mississippi, North Carolina, South Carolina, Tennessee, Texas, and Virginia. (Only data from the southern U.S. is publicly available for the past year). According the report, the total expected demand for wood biomass increased by 10 million green tons, a 76 percent hike in wood biomass demand across the region.

“The science clearly shows that not all sources of biomass are equal in terms of their climate change impacts,” said Will McDow, manager of EDF’s Southeast Center for Conservation Incentives, and a member of both the North Carolina Forestry Technical Advisory Committee and Forestry Council. “The industry has known that EPA was planning to include biogenic emissions in permitting requirements in some way since last spring, yet this fact clearly has not dampened investors’ enthusiasm for bioenergy in 2010.”

McDow concluded, “The stakes are too high for EPA to rush to judgment in making biomass emission rules because these biomass plants will produce greenhouse gas emissions for 20 to 30 years. EPA needs to take the time to get the accounting right for biomass emissions to spur the right investments and policies our nation needs to protect forest sector jobs and the natural resources we depend upon.”