Recently, I provided oral testimony to the EPA on behalf of the Dogwood Alliance and the forests and the communities we serve. I thanked the earnest members of the panel for their work to develop the Clean Power Plan (CPP) and expressed our strong opposition to forest-based biomass being included as suitable compliance pathway in Federal Implementation Plan for the Clean Power Plan. The Clean Power Plan has the ability to create a lasting legacy and it is evident that the ideals of the CPP are grounded in a moral obligation to citizens and future generations. However, I made sure to articulate that the inclusion of biomass takes us backwards and may actually undermine its intended purpose.  Here are just a few reasons why….

Burning Wood for Electricity Does Not Reduce CO₂ Emissions

Burning wood and other forms of biomass in a power plant produces about 3,000 pounds of CO₂ per megawatt-hour—an emissions rate that is approximately fifty percent higher than that of a coal-fired power plant. Accordingly, biomass combustion does not reduce CO₂ emissions and should not be considered part of the Best System of Emissions Reduction (BSER) envisioned in the Clean Power Plan.

EPA is requiring that to be qualified, biomass must be “demonstrated as a method to control increases of CO2 levels in the atmosphere,” but the agency hasn’t established required parameters and methods for how states might accurately demonstrate this and this ambiguity might incentivize more states to look to forest-based biomass given a perceived relative ease in meeting a definition for what it might mean for biomass to be “qualified.”

Diverting Important Momentum for Wind, Solar, Efficiency, etc.

By enabling and promoting forest-based biomass as a compliance pathway, EPA is potentially diverting continued momentum for scientifically-grounded and non-controversial solutions such as wind, solar, energy efficiency, geothermal, tidal, etc. It is our hope that the FIP will contain the kinds of incentives and clear guidance that will spur continued technological innovations and investments in these proven and less controversial renewable energy pathways that further bring down the costs of these important technologies and support their widespread expansion.

Flawed Policies Can Have Lasting Effects – A Case Study in the Southeast US

EPA only needs to look to the Southeast to see evidence for what happens when you treat bioenergy as having zero emissions. Driven by flawed renewable energy directives in the EU (with the UK being a primary driver), the volume of wood pellet exports from the US Southeast have quadrupled in the past several years. Projections of continued growth in Western Europe led by the UK are staggering and are estimated to jump from 5 million tons in 2015 to over 35 million tons in 2020.[1]

Countless investigations have directly linked wood pellet manufacturing in the Southeastern US to the accelerated logging of forests, including in sensitive ecosystems such as mature bottomland hardwood and wetland forests[2]. Still, industry insists they use “logging residuals”, “scraps” and “waste wood”.  Yet, it is estimated that 75% of the feedstock used to manufacture wood pellets in the Southeast comes from ‘roundwood’, or whole trees[3].  These facilities simply cannot reach their desired output with residuals, byproducts, and scraps as they claim. In fact, USFS reports project not only accelerated logging across the region but also the loss of natural forests to plantations, if the biomass industry continues to expand[4]. These trends in wood pellet manufacturing are especially troublesome given recent global maps showing that forest disturbance from logging in the Southeastern US was four times that of South American rainforest from 2000-2012[5].

Communities Are Concerned and Organizing

Biomass incineration creates fine particulate pollution that impacts human health. Additionally, these pellet production facilities and biomass incineration plants are often located in relative close proximity to communities. Dogwood is increasingly supporting community-led efforts to push pack proposed facilities and many residents see this as an environmental justice concern.

We Need to Protect Forests Instead of Opening Up the Flood Gates to Burn Them

Beyond biodiversity, standing Southern forests remove carbon from the air, provide critical flood control and protect water resources, services that are critical to both achieving carbon emission reductions necessary for avoiding the most catastrophic effects of climate change and ensuring community resiliency in the wake of a changing climate.  Forests represent our best defense against climate change. Now is not the time to open the flood gates for forests to be used as fuel for electricity. Instead, we need to accelerate efforts to protect our forests and improve ecosystem health.

Hopefully, the EPA will listen to the concerns of national, regional, and local organizations on this issue by not building forest-based bioenergy into the Federal Implementation Plan.

[1] http://www.wwrgroup.com/en/biomass-market/the-wood-pellet-market

[2] http://www.dogwoodalliance.org/wp-content/uploads/2015/06/Wetlands-Logging-Investigation-Flyer.pdf

[3] European Commission Workshop Briefing Paper Sept 2015: Study on the Environmental Implications of the Increased Reliance of the EU on Biomass for Energy Imported from North America

[4] http://www.srs.fs.usda.gov/pubs/gtr/gtr_srs202.pdf

[5] http://www.sciencedaily.com/releases/2013/11/131114142123.htm