I am writing to urge this Administration to deny any expansion of the wood pellet industry in North Carolina and to immediately address the environmental justice implications of this proposed facility. I urge the Administration to address the impacts this facility would have on the climate, on North Carolina forests, on biodiversity, and on the health and well-being of impacted residents. Specifically, I call on this Administration to:

• Complete a full Environmental Justice Report, which includes a disparate impact analysis of the Active Energy Renewable Power (AERP) proposed operation that takes into consideration its predicted increased production volume and coinciding pollution and cumulative impacts.
• Delay the public hearing until the COVID-19 crisis has passed and an in-person public hearing can be safely held.
• Deny Active Energy Renewable Power’s air quality permit to build and operate a black wood pellet production plant in Lumberton, North Carolina.
• Put a moratorium on any expansion of the industrial wood pellet industry in North Carolina.

Climate Impacts

Dogwood Alliance urges this Administration to consider the impacts this facility will have on North Carolina’s forests, the state’s ability to be resilient in the face of increasing storms and hurricanes, and our commitment to reduce carbon emissions. While climate action is a top priority of the Cooper Administration, dirty industries continue to expand, and protections for forests fall short. Last year, Enviva, the world’s largest wood pellet producer, was approved for three massive expansions in North Carolina. The continual permitting process of industries that are scientifically proven to be carbon polluting impedes North Carolina’s executive order to reach a 40% emissions reduction goal by 2025. Wood pellet production is carbon-intensive, leads to energy production that is carbon-intensive, and removes forests that store and sequester carbon.

AERP is applying for a permit to produce 40,000 tons of torrefied wood pellets per year. However, AERP’s website indicates plans to increase production to 400,000 tons per year. If AERP is permitted and their intended expansion goes through, this facility will increase logging by 9,600 acres per year and emit 73,2782 tons of CO2e per year, the equivalence of over 155,580 extra cars on the road.

Many forms of biomass—especially from forests—produce higher carbon emissions compared to fossil fuels. In particular, a growing body of peer-reviewed, scientific studies shows that burning wood from whole trees in power plants to produce electricity can increase carbon emissions relative to fossil fuels for many decades—anywhere from 35 to 100 years. This time period is significant: the Intergovernmental Panel on Climate Change made it clear that the coming decade is crucial and requires dramatic short-term reductions in greenhouse gases. The emissions from biomass will persist in the atmosphere well past the time when significant reductions are needed.

Additionally, industrial logging and wood product manufacturing emit enormous quantities of greenhouse gases and have significantly depleted the amount of carbon sequestered and stored on the land. Each year, roughly 200,000 acres of forestland in North Carolina are clearcut to feed global markets for wood pellets, lumber, and other industrial forest products. CO2 emissions from logging and wood products are a major missing component of North Carolina’s greenhouse gas inventory. Emissions from the release of carbon in wood products, forgone sequestration capacity, decay of logging residuals, and fertilizer likely top 44 million metric tons of carbon dioxide each year, making this sector the third most carbon intensive in the state.

Forest & Wildlife Impacts

Global demand for wood pellets is devastating forest ecosystems in the Southeast United States. Biomass facilities acknowledge that they harvest from wetlands, highly diverse habitats with many threatened mammal, reptile, amphibian, and bird species. Despite industry claims, independent reporting shows a disturbing pattern: wood pellets are often sourced from wood that is harvested from native hardwood forests in an area designated as a global biodiversity hotspot.

Demand for softwood and pine plantations is also having a negative impact on forests, the climate, and biodiversity. Since 1953, the government has used various programs to pay landowners to plant pine instead of allowing natural forests to grow. As a result, we’ve lost over 35 million acres of natural forest and gained over 40 million acres of pine plantation instead. In addition, industrial tree plantations pose a serious threat to North Carolina’s climate change resiliency because they make the effects of floods, droughts, heat waves, storms, and disease more severe.

Environmental Justice Impacts

Similar to other wood pellet production facilities in North Carolina, which are all located in environmental justice-designated communities, Robeson County is 42% Native American, 24% African-American, and is ranked worst in the state for health outcomes. Robeson County is one of the most frequently flooded counties in the state, and many residents are still recovering from devastating losses from Hurricanes Florence and Matthew.

Based on the Environmental Justice (EJ) Snapshot, the community targeted within the two-mile buffer of AERP’s proposed wood pellet facility in Lumberton is an “underserved community” as defined by DEQ’s Public Participation Plan and therefore must be afforded the “enhanced engagement methods” that Plan prescribes. In addition, DEQ must also complete a full EJ Report, which includes a disparate impact analysis of AERP’s proposed operation that takes into consideration its predicted increased production volume and coinciding pollution and cumulative impacts. It will be impossible for DEQ to meet its Title VI obligations of fair treatment and meaningful involvement without that full report and without allowing additional time after the COVID-19 state shutdown is over to inform and engage the community (as the Plan requires) about the proposed facility, the pollutants it will expose the community to, cumulative impacts of surrounding industrial operations, and data about the community’s health vulnerabilities. The public hearing must be delayed until after the full EJ report is made publicly available so that community members may be meaningfully involved in DEQ’s decision-making process regarding this permit.

Conclusion

If AERP is permitted to operate in Robeson County, it will have impacts on the health of local residents, the ability of natural ecosystems to support greater resiliency to storms and hurricanes, and contribute to global carbon emissions at a time when community health and safety rely on cutting those emissions. Impacted residents deserve an opportunity to be informed about this facility and ask questions to North Carolina Department of Environmental Quality (NC DEQ) staff.

We reiterate our requests that NC DEQ suspend the public hearing until COVID-19 health experts indicate it is safe to assemble in person and until after a full Environmental Justice Report has been completed. Ultimately, we urge this Administration to deny this permit and to put a moratorium on the expansion of any industrial wood pellet facilities in North Carolina.

Thank you for the opportunity to comment on this permit.

If you’d like to submit your own public comment, please complete this action.