The Massachusetts Department of Energy Resources’ (DOER) “Proposed Final Renewable Portfolio Standard Regulations” effectively eliminate biomass as a renewable energy source and are out of step with the rest of the country, according to the National Alliance of Forest Owners (NAFO) as detailed in their comments submitted to DOER.
“Massachusetts stands alone in effectively eliminating biomass as a carbon beneficial, source of renewable domestic energy in its proposed rule,” said Dave Tenny, NAFO president and CEO. “The state has chosen to bypass the mainstream view of the forest carbon cycle in energy production, and relies instead on the selective use of assumptions that distort how the forest carbon cycle works. When considered at scales relevant to real-world forest management, the prevailing science is clear that the sustainable use of forest biomass for energy does not increase net carbon in the atmosphere.”
The U.S. is a global leader in sustainable forest management. Over the last 50 years modern forestry has increased the total carbon stored in U.S. forests by 49 percent as forest owners in the U.S. consistently grow more trees than they harvest, including the planting of more than 3.5 million trees in the U.S. every day.
“The U.S. Environmental Protection Agency, the International Panel on Climate Change, the World Resources Institute and other reputable organizations around the world recognize the well-established benefits of replacing fossil fuels, which produce a one-way emission of carbon into the atmosphere, with forest biomass, which naturally cycles carbon between forests and the atmosphere,” Tenny stated. “The Massachusetts approach seems to take the opposite view, suggesting that fossil fuels are more carbon beneficial than biomass. We join the mainstream in rejecting this position.”
The regulations set forth by Massachusetts effectively preclude biomass as a renewable energy source by setting infeasible efficiency requirements, imposing arbitrary restrictions on the amount of biomass used for energy, and requiring unrealistic verification requirements. The regulations also rely on assumptions for measuring biomass carbon emissions that have been criticized by many because they fail to incorporate modern forestry practices, which occur at a landscape level and over long periods of time. Combined, these requirements add significant complexity, cost and uncertainty that will likely make biomass energy uncompetitive in the marketplace. Limited market opportunities for working forests will likely reduce investments in forest health management and the economic competitiveness of private forests with other land uses.
“History shows that new markets for forest products increase rather than decrease overall carbon in our forests,” Tenny concluded. “By discouraging rather than encouraging biomass energy, the Massachusetts policy eliminates economic returns that support investments in forest health and compels forest owners to consider alternative land uses that are more economically competitive. If Massachusetts wants to preserve the carbon benefits of working forests, it should send positive market signals to biomass producers. As it stands, the state is sending those signals to fossil fuel producers.”
NAFO is an organization of private forest owners committed to advancing federal policies that promote the economic and environmental benefits of privately-owned forests at the national level.NAFO membership encompasses more than 80 million acres of private forestland in 47 states. Working forests in the U.S. support 2.5 million jobs. To see the full economic impact of America’s working forests, visit www.nafoalliance.org/economic-impact-report.