As the year winds down and the U.S. Environmental Protection Agency's (EPA) efforts intensify on amendments to its greenhouse gas regulations (commonly referred to as the "Tailoring Rule") addressing the unique carbon attributes of wood biomass, the agency will undoubtedly receive plenty of advice on how to develop a "good" policy that squares with the prevailing science. What constitutes "good" is usually in the eye of the beholder, and EPA has a range of policy options to consider. However, there are a number of fundamentals the agency must apply to craft a policy that is supported by sound science while providing a practical path toward true carbon benefits from biomass energy.
logs for combustion in a biomass oven
1. Carbon accounting methods should clarify rather than distort the carbon picture. The science is conclusive that biomass energy provides significant carbon benefits compared to fossil fuels. More than 100 notable scientists made this point in a letter to EPA when the agency first published the Tailoring Rule. However, the debate beneath the science, to the extent there is one, focuses on how the agency should construct a carbon accounting framework - the policy tool the agency will use to determine the carbon impacts of biomass energy.
Framework questions focus on factors such as timeframes (e.g., longer or shorter), the size of the forest area considered (e.g., a single tree or stand, a landscape, a region or the nation as a whole), and how to count carbon change (e.g., against a point in time reference using actual data or along a continuum using assumptions and algorithms) that can sometimes be manipulated to distort the full carbon picture. In some instances these distortions are presented as “new” science when they are merely the outcome of policy preferences. Yet, when considering the available options for carbon accounting, most carbon experts agree that shorter timeframes, smaller land areas and overly complicated measuring approaches, distort the carbon picture - in some cases to suggest that fossil fuels are more carbon beneficial than biomass. Conversely, longer timeframes, larger land areas and the reliance on data over assumptions consistently provide a more clear and precise carbon picture better reflecting the full long-term benefits of biomass energy.
2. Strong markets provide forest carbon benefits by promoting forest retention and reforestation. Data consistently show that markets for forest products and services provide a powerful incentive to retain privately owned forests as forests. Forest owners make management decisions, such as when, how and whether to replant, based on market outlook. Simply speaking, when markets are strong, forests thrive. That is why from 1953 to 2011, when society demanded the most from our forests, overall forest extent in the U.S. remained constant and the total volume of growing trees increased by 50%.
3. Carbon beneficial bioenergy markets are developing gradually and rely on clear policy signals to remain viable. Reliable data show that bioenergy production in the U.S. is much more gradual today than the boom projections of recent years anticipated. New bioenergy plants are emerging in “wood baskets” where traditional facilities have closed and where wood supply is plentiful. As this market matures, it is crucial that federal policy remove the cloud of uncertainty that hangs over weary investors and send a clear, unambiguous message that biomass energy is a welcome part of our nation's overall energy mix, both because it is renewable and because it is carbon beneficial.
4. Forest economics will maximize carbon benefits by driving low rather than high value material toward bioenergy. Bioenergy provides an economically important end use for low value biomass but is a poor option for higher value wood. Projections that energy markets will drive large scale conversion of sawtimber plantations into biomass plantations that store less carbon simply don't pencil out. Market data show that a marginal increase in wood demand for biomass used in energy production will comprise between 4% and 9% of overall wood consumption of forest materials in the U.S. by 2023 and will consist primarily of forest residuals and pulpwood. Even using conservative price assumptions for high value wood, the demand for biomass for energy would have to double beyond current projections to make the conversion of sawtimber plantations to bioenergyplantations even marginally economic.
5. The use of biomass for energy is a sustainable forest practice with long-term carbon benefits. Forest sustainability is a concept that applies to forestry as a whole and is not segregated among wood uses. It is also a concept that works hand-in-hand with forest economics. Just as strong markets promote forest growth and retention, so too do they promote investment in sustainable forest practices that produce healthier trees capable of storing more carbon in shorter timeframes. Market data show that bioenergy markets will strengthen rather than threaten net forest growth over the long term. However, experts warn that a significant and growing threat to forest sustainability and the associated carbon benefits is declining markets that push forests into non-forest uses.
There is no question that EPA has a challenging task in the weeks ahead. However, by applying these fundamentals, the agency can apply sound science working with rather than against emergingbioenergy markets. The outcome will be a practical policy that promotes more renewable energy, more healthy forests and a better climate.