WASHINGTON, DC – David P. Tenny, President and CEO of the National Alliance of Forest Owners, urged the Senate to help send clear and positive policy signals to the biomass energy community in testimony today before the Senate Committee on Agriculture, Nutrition, and Forestry at its hearing today entitled, Empowering Rural Communities, the Status and Future of the Farm Bill’s Energy and Rural Development.

On behalf of America’s private forest owners, Tenny reminded the Committee of the benefits of renewable forest biomass and urged them to support a broad definition of qualifying forest biomass and to urge EPA to modify its GHG Tailoring Rule so that biomass energy is not treated the same as fossil fuel energy, such as oil and coal, in Clean Air Act regulations. Tenny testified:

NAFO’s members are the nation’s forestry leaders. They recognize the fundamental role sustainably managed forests can play in renewable energy policy. They are well positioned to provide a plentiful domestic source of sustainable and carbon beneficial renewable energy.

Our nation has reached a critical point in the debate on renewable energy. We are deciding whether we will embrace our full renewable energy potential or not. If we are truly committed to renewable energy, then our policy will reflect that commitment. We will optimize the potential of each renewable energy source as well as the potential of each region of the country to produce renewable energy. Working forests are well positioned to help achieve that potential.

In order to make these significant contributions, working forests need clear policy signals from Congress and the Administration.
The Farm Bill has helped establish a level playing field among renewable energy sources by providing an inclusive definition of qualifying biomass. This sends the clear message to forest owners that their contributions are both welcome and encouraged.
Yet, notwithstanding the positive signals provided by the Farm Bill, other federal policies are sending a chilling signal to forest owners undoing the forward momentum this committee has tried to establish.

The biomass definition in the Energy Investment and Security Act of 2007 (EISA) constrains biomass utilization on up to 90% of private forests in the U.S. This has softened investments in biofuels from forest biomass at a time when they are needed to commercialize breakthrough technologies.

Similarly, the EPA’s sudden shift in the treatment of carbon emissions from biomass energy in the PSD Tailoring Rule creates significant confusion in the marketplace by treating carbon emissions from biomass energy like fossil fuel emissions. EPA’s ambivalence about how to account for carbon emissions from biomass energy conflicts with well established international conventions, greenhouse gas inventory data, and EPA’s own statements recognizing that biomass energy in countries, like the U.S., where forests are a net carbon sink, does not increase carbon in the atmosphere.

NAFO applauds the Chairman, Ranking Member and other members of this Committee for their recent letter to Administrator Jackson opposing EPA’s position in the Tailoring Rule (PDF).

NAFO also appreciates the commitment made by the Secretary of Agriculture concerning the role USDA will play in the review of the Tailoring Rule. NAFO looks forward to full USDA engagement to establish a strong record supporting the treatment of forest biomass energy as carbon neutral under the Clean Air Act so long as national forest carbon stocks are stable or increasing.

NAFO urges this committee to retake the initiative on forest biomass energy and help correct the policies that have put forest biomass on the back burner.

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NAFO is an organization of private forest owners committed to advancing federal policies that promote the economic and environmental values of privately-owned forests at the national level. NAFO membership encompasses more than 75 million acres of private forestland in 47 states. View NAFO’s interactive map to see the economic impact of America’s working forests.

WASHINGTON, DC – David P. Tenny, President and CEO of the National Alliance of Forest Owners, issued the following statement today on EPA’s Call for Information on Greenhouse Gas Emissions Associated with Bioenergy and Other Biogenic Sources:

“The EPA’s response to the requests of key stakeholders and the admonitions of Congress is welcome. However the announced action is a very modest step forward and does not convey a sense of urgency. We continue to call upon EPA to suspend application of the regulation to greenhouse gas emissions from biomass facilities while developing its policy, as many stakeholders and members of Congress have requested.

“We are at a critical juncture at which both policy makers and the marketplace are considering our nation’s path forward on renewable energy. EPA must act quickly to clarify the treatment of biomass energy under the Tailoring Rule and remove the confusion resulting from their sudden and significant shift in policy. Each moment of delay jeopardizes existing and future investments in low carbon biomass energy that are essential to meeting our national renewable energy goals and reducing our dependence on high carbon emitting fossil fuels.

“References by the EPA to greenhouse gas inventories and international conventions and protocols acknowledged by experts as the most accepted approaches to accounting for carbon emissions from biomass energy is appropriate. These set as a baseline the internationally accepted position that accounting for carbon emissions from forests for all uses, including energy production, is most appropriately done at the national scale rather than through site-by-site analyses that can easily create a distorted picture of the forest carbon cycle.

“NAFO looks forward to contributing to the already significant body of information demonstrating the carbon benefits of biomass energy. NAFO also looks forward to the earnest engagement of the U.S. Department of Agriculture, which is well positioned to vigorously represent the contributions of agriculture and forestry to produce renewable energy that significantly reduces overall greenhouse gas emissions. It will be critical for EPA and USDA to work together and to work quickly. Our nation’s renewable energy future is waiting.”

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WASHINGTON, DC – David P. Tenny, President and CEO of the National Alliance of Forest Owners, offered the following comments on the Forest Sustainability in the Development of Wood Bioenergy in the U.S. study released today by the Pinchot Institute for Conservation and H. John Heinz III Center for Science, Economics and the Environment:

Forest biomass is a domestic, sustainable, and carbon-friendly source of renewable energy that is fundamental to our energy security. The Pinchot/Heinz study raises a number of questions that have been common to the ongoing policy discussion on the use of biomass for energy, providing a point of view that will contribute to the national dialogue.

While the Pinchot/Heinz study does not reach any conclusions about biomass, it frames the questions for which a significant body of information is available to inform policy makers. This includes studies that sharpen our understanding of potential demand for biomass, how biomass supply will increase in response to increased demand, existing environmental safeguards for sustainable biomass production and the climate change benefits of forest biomass as a carbon neutral energy source.

Often overlooked in the discussion of how to sustainably produce biomass for future energy needs is the historic relationship between private forests and markets for forest products that forms a cornerstone of the American success story in sustainable forest management and has helped make the United States a world leader in sustainable forestry. Markets provide a powerful conservation tool for sustaining forestland by enabling private forest owners to invest in sustainable forest practices and keep their land in forest rather than being compelled to convert it to non-forest uses.

The results of this relationship speak for themselves. U.S. forests have been stable or increasing for a century and the standing volume of trees in our forests has increased 50 percent over the last 50 years. It is because of strong markets for forest products that our forests today are so well positioned to help meet the growing renewable energy demands of the future and serve as a primary source of climate change mitigation. The advent of new markets for renewable biomass energy simply opens a new chapter in our nation’s ongoing success story of sustainable forest management through strong and diverse forest products markets.

Recent studies (here) answering questions raised in the Pinchot/Heinz report include:

Ecological sustainability – The National Council for Air and Stream Improvement describes how biomass energy harvests are ecologically sustainable under current frameworks in the United States.

Forest landowners’ response to energy markets – The University of Georgia and North Carolina State University explain how landowners will likely respond to biomass energy markets, particularly in the U.S. South and Northwest, concluding that new markets will enable forest landowners to invest in forest management practices that will improve forest productivity to sustainably meet increased supply needs.

Likely forest bioenergy demand by 2020 – Forisk Consulting, one of the leading U.S. firms in economic forecasting, has developed a data-driven methodology to predict the amount of announced bioenergy capacity that will likely be in production by 2020. They conclude that approximately 36% of the capacity announced today will result in new bioenergy production in the next ten years.

Carbon benefits – The National Council for Air and Stream Improvement uses the prevailing conclusions of contemporary science to explain why renewable forest biomass energy is beneficial to atmospheric carbon as part of the natural carbon cycle.

Environmental regulation of private forests in the U.S. – The National Alliance of Forest Owners provides a concise summary of existing laws, regulations, and non-regulatory policies at the federal, state and local level that provide the framework for sustainable forest management in the United States and that enable the U.S. to be a world leader in sustainable forest management.

This information is summarized and available on NAFO’s website at www.nafoalliance.org/studies.

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NAFO is an organization of private forest owners committed to advancing federal policies that promote the economic and environmental values of privately-owned forests at the national level. NAFO membership encompasses more than 75 million acres of private forestland in 47 states. View NAFO’s interactive map to see the economic impact of America’s working forests.

“EPA’s action was a sudden shift in direction that appeared to ignore the treatment of biomass energy cited in the draft rule,” said David P. Tenny, President and CEO of the National Alliance of Forest Owners. “We were surprised along with many others that EPA would place renewable biomass, which plays such a fundamental role in moving our nation toward a more reliable supply of domestic, low carbon renewable energy, in the same category as coal, oil and other non-renewable, high carbon fuel sources.”

The letter explains how biogenic carbon emissions, in contrast to fossil fuels, are part of the natural carbon cycle, “Biogenic carbon is part of a relatively rapid natural carbon cycle. Trees and other plants absorb carbon as they grow. Combustion of harvested biomass for energy releases previously stored carbon back into the atmosphere, which the growing biomass re-absorbs. Where national data show stable or increasing carbon stocks in forests and agricultural lands, as in the United States, the result is no net increase of carbon in the atmosphere. . . EPA and other federal agencies have recognized the carbon neutrality of biomass emissions for many years.” The letter also points out that, “EPA’s Renewable Fuel Standard 2 demonstrates there are additional benefits associated with biomass throughout the lifecycle compared to fossil fuels.”

“We have reached an important juncture when our nation is deciding its energy future. An important part of that decision is identifying the energy sources that will make us more independent and sustainable for the long run,” Tenny said. “Now is the time for EPA and others in government to firmly establish biomass as one of the critical paths to the future and work cooperatively with the biomass community to make that future a reality. The confusion created by the EPA’s Tailoring Rule is a significant step backward and puts the biomass community at risk of erroneously being cast as part of the problem rather than part of the solution. The EPA must act quickly so we can resume forward progress rather than unnecessarily spinning our wheels over an already settled area of policy.”

The cosigners remind Jackson that the forest products industry supplies 65% of its own energy needs with renewable biomass and that the, “unprecedented step of equating biomass carbon emissions with fossil fuel carbon emissions. . . threatens to chill investment in varieties of trees, grasses and other plants that could be purpose-grown for energy production. This will frustrate the environmental goals of shifting to renewable energy.” The cosigners also ask Jackson for an expeditious, “public review of biogenic carbon neutrality and its role under the Clean Air Act using as its baseline the long-standing positions of EPA and other federal agencies,” and to, “suspend application of greenhouse gas emission regulation to facilities with biomass combustion until this review has been completed.”

The full letter, including all 163 cosigners, is available on NAFO’s website (PDF).

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NAFO is an organization of private forest owners committed to advancing federal policies that promote the economic and environmental values of privately-owned forests at the national level. NAFO membership encompasses more than 75 million acres of private forestland in 47 states. View NAFO’s interactive map to see the economic impact of America’s working forests.

The carbon benefits and sustainability of energy from renewable forest biomass is documented in recent white papers available on NAFO’s website at www.nafoalliance.org/studies.

WASHINGTON, D.C. – David P. Tenny, President and CEO of the National Alliance of Forest Owners, offered the following comments on the Biomass Sustainability an Carbon Policy Study released yesterday by the Manomet Center for Conservation Sciences and the concurrent statement released by the Massachusetts Department of Energy Resources:

NAFO appreciates the effort by Manomet to analyze the carbon impacts of using forest biomass for energy. The Manomet study adds to the significant body of science affirming that, over time, the sustainable use of renewable forest biomass for energy does not increase carbon in the atmosphere and has significant carbon benefits over fossil fuels because it recycles atmospheric carbon. These facts have been recognized throughout the world for a long time and are a cornerstone of conventional renewable energy policy.

In contrast, the conclusions drawn from this study by Massachusetts confuse rather than inform public policy by suggesting that fossil fuel energy that increases atmospheric carbon over the long term is preferable to renewable forest biomass energy that recycles and reduces atmospheric carbon.

Manomet observes that, although forest biomass releases carbon when it is used for energy, it is unique because, ‘unlike fossil fuels, forests can grow back and recapture (or sequester) CO2 from the atmosphere. Over time, through accelerated forest growth, the carbon debt can be ‘paid off’. . . and the use of wood for energy then becomes increasingly beneficial for greenhouse gas mitigation. As a result, using wood for energy can lead to lower atmospheric greenhouse gas levels than fossil fuels.’

Forest carbon stocks in the U.S. have been increasing annually for over 50 years notwithstanding our nation’s growing reliance on forests for a variety of uses, including energy. In contrast, fossil fuels have steadily added carbon to the atmosphere during this timeframe. Modern forestry uses low value forest material for energy while using mature trees to produce products, like homes and furniture, that store carbon for long periods. This combination increases and accelerates the carbon benefits to the atmosphere when forests regrow, making the comparison to fossil fuels even more dramatic.

Massachusetts’ determination that fossil fuels are preferable over renewable biomass for energy is a policy decision unique to the state, not a broad scientific conclusion. The prevailing science is clear on the carbon benefits of producing energy from sustainable forest biomass as compared to fossil fuels. Over the long term our nation will be better served by increasing its use of an energy source, like forest biomass, that recycles atmospheric carbon than burning more fossil fuels that don’t.

The carbon benefits and sustainability of energy from renewable forest biomass is documented in recent white papers available on NAFO’s website.

Forisk Consulting, a leader in economic forecasting in the forest products industry, developed a practical, data-driven screening methodology examining siting, financing, permitting, sourcing of raw materials, and other factors, that shows that the ramp-up of renewable energy production will likely be gradual.

David P. Tenny, President and CEO of NAFO, said, “As policy makers work to develop responsible biomass energy policy, they rely on realistic projections of demand in order to tailor policy to real world conditions. Forisk’s screening methodology gives us a more accurate approach to predicting the build out of biomass energy capacity from the many projects that have been announced. With this tool, policy makers can craft better public policy, and the public can have a more realistic view of the future.”

Dr. Brooks Mendell, President and Founder of Forisk Consulting, explained, “Locating, financing, constructing and operating these projects goes beyond drafting a pro forma and wishing on a star. The reality is complicated and difficult. We developed this methodology to help forest owners assess likely demand from new wood bioenergy markets in the future. Through our partnership with NAFO, this white paper introduces the tool to policy makers.”

The methodology for screening wood-consuming projects focuses on two criteria that emphasize the practical realities of developing bioenergy markets: technology and status:

• Technology: Projects that employ currently viable technology pass the technology screen. These include pelletizing technology and wood-to-electricity projects. Cellulosic ethanol from wood feedstock, as a developing technology, is not yet considered operational using this tool.
• Status: Projects that are operational, under construction, or received or secured two or more necessary elements for advancing towards operations pass the status screen.

Forisk publishes a monthly summary projecting demand from wood-consuming bioenergy facilities. As of May 2010, 135 announced or operating wood-consuming bioenergy projects in the U.S. South represent 55.9 million tons per year of announced capacity. Using the Forisk screening methodology, approximately 20.3 million tons per year of capacity, or 36% of the announced capacity, is predicted to be in operation by 2020. In Summer 2010, Forisk’s periodic state-specific updates will expand beyond the U.S. South to cover the continental U.S.

The whitepaper and the most recent projection are available at www.nafoalliance.org/bioenergy-tracking-guide/.

This work compliments other recent studies on biomass energy, including supply-side projects; ecological sustainability; and, carbon neutrality. All of this research is available at www.nafoalliance.org/studies.

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NAFO is an organization of private forest owners committed to advancing federal policies that promote the economic and environmental values of privately-owned forests at the national level. NAFO membership encompasses more than 75 million acres of private forestland in 47 states. View NAFO’s interactive map to see the economic impact of America’s working forests.

Forisk Consulting specializes in analyzing the supply and demand characteristics of local wood and timber markets, and the financial performance of timberland investment vehicles. Forisk produces analytical products and provides research and educational services to operating, finance and strategy executives and analysts making decisions associated with timber REITs, timberlands, and wood-using bioenergy and manufacturing facilities.

“The EPA and the Department of Energy, through their own data collection, have long recognized that biomass combustion for energy does not increase carbon in the atmosphere. The EPA has concluded that there is a ‘scientific consensus’ that ‘carbon dioxide emitted from burning biomass will not increase CO2 in the air if it is done on a sustainable basis.’

“The United States is a world leader in sustainable forest management. As a result, our volume of growing trees has increased by nearly 50 percent over the last 50 years and each year our nation stores more carbon in its forests than it releases from them. That is why energy from forest biomass does not increase carbon in the atmosphere.

“Regulating biomass energy the same as fossil fuels would be a significant shift in federal policy and a powerful disincentive to use biomass to address our nation’s renewable energy and climate needs. The economic impacts on forest owners, mills using biomass energy and rural jobs would be significant, and the resulting devaluation of private forests could increasingly force this land into more economically competitive alternative uses with far fewer GHG mitigation benefits.

“We appreciate Secretary of Agriculture Vilsack for addressing this issue with EPA and committing to work with EPA to develop a policy that embraces biomass energy and avoids unnecessary and counterproductive regulation. We look forward to working with USDA and the EPA to harness the benefits of biomass energy as a fundamental part of our nation’s energy and climate solution.”

For more information, read NAFO’s comments to EPA on the draft rule and a white paper on biomass carbon neutrality are available.

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NAFO is an organization of private forest owners committed to advancing federal policies that promote the economic and environmental values of privately-owned forests at the national level. NAFO membership encompasses more than 75 million acres of private forestland in 47 states. View NAFO’s interactive map to see the economic impact of America’s working forests.

David P. Tenny, President and CEO of NAFO, said, “Chip brings a depth of experience with the land that is unrivaled in the forest policy world.  His knowledge combined with his proven track record for working with partners to seek common sense solutions will help America’s private forest owners lead the way in building a strong future for forest owners and their contributions to renewable energy, climate change mitigation, conservation and traditional markets.”

Chip will be responsible for policy development and working with partners, federal agencies and others to advance NAFO’s priorities.  Additionally, he will serve as internal legal counsel to NAFO on policy, advocacy, and administrative matters. Chip joins NAFO on May 10, 2010.

Chip currently serves as Deputy General Counsel and Executive Director of forestry issues for the American Forest & Paper Association, where he has worked since 1989.  During the past 20 years, Chip has managed key forestry programs related to species habitat, clean water and sustainable forest management.  He also established the legal support program for both private and federal forestland.  Prior to that, he held the position of Assistant Solicitor in the U.S. Department of the Interior, preceded by service as a staff attorney in the Interior Office of the Solicitor and Interior Board of Land Appeals.  He is a past chair of the American Bar Association’s Forest Resources Committee.  He earned both his legal and undergraduate degrees from Georgetown University.

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NAFO is an organization of private forest owners committed to advancing federal policies that promote the economic and environmental values of privately-owned forests at the national level. NAFO membership encompasses more than 75 million acres of private forestland in 47 states. See the economic impact of America’s working forests on an interactive map.

David P. Tenny, President and CEO of NAFO, highlighted the need for renewable biomass energy, “Tax policy must support forest biomass energy as an essential means of achieving our renewable energy goals.  Forest biomass provides a critical source of base load energy to complement intermittent sources, like wind and solar, and is the only viable renewable energy source in many parts of the country. Putting all renewable energy sources on a level playing field in the tax code will enable us to develop the resources that are best suited to, and most economic for, each area of the country.”

NAFO’s statement to the Committee highlighted its support of H.R. 2626, introduced by Representatives Meek, D-17-Fla., and Herger, R-2-Calif., which would equalize tax credit rates for all renewable technologies under the Section 45 Production Tax Credit. Biomass is presently eligible for 50 percent of the tax credit available to other sources, such as wind and geothermal.  Tenny underscored how the market responds, “In too many cases renewable electricity projects are selected based more on the comparative value of the tax credit than on the viability of the technology for the region.  Congress should equalize tax policy so that project decisions can better focus on optimizing renewable energy production through the most viable energy source.”

Tenny also highlighted its benefits, “Scientists and other federal and private sector experts recognize that sustainable production of forest biomass energy is critical to realizing our greenhouse gas reduction goals, because it recycles atmospheric carbon rather than adding to it.  In addition, it is sustainable, domestic, and renewable.  The tax code should support what the experts have told us.”

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NAFO is an organization of private forest owners committed to advancing federal policies that promote the economic and environmental values of privately-owned forests at the national level. NAFO membership encompasses more than 75 million acres of private forestland in 47 states.  Visit www.nafoalliance.org/economic-impact-report to see the economic impact of America’s working forests.

The BCAP is important because it supports energy from renewable forest biomass, which is sustainable, domestic, renewable, and, according to the EPA, does not increase CO2 in the air if used sustainably.[i] Additionally, it is a vital component to our nation’s energy security goals, with projections that it will be required to meet as much as one-third of a renewable electricity standard.

“BCAP’s investment in the forest biomass supply chain is critically needed and will help establish the infrastructure and associated jobs necessary to support the growing renewable energy sector,” noted David P. Tenny, President and CEO of NAFO.  “Historically, there have been limited market opportunities for forest-derived biomass.  As a result, the supply chain supporting this material is relatively immature and fragmented compared to its potential.  Through BCAP investments, we can develop this critical infrastructure, build jobs in rural communities, and position our nation to produce more renewable energy in a sustainable and cost-effective manner.”

NAFO members that participated in the BCAP’s 2009 Collection, Harvest, Storage, and Transportation (CHST) Matching Payment Program report that the program has in many instances helped accelerate the development of critical infrastructure and jobs in the biomass supply chain, thereby improving the ability of eligible material owners to produce and deliver forest biomass to conversion facilities.

Tenny added, “We have noted and applaud USDA’s leadership in seeking ways to revitalize rural economies.  Based on our early experiences with BCAP, we believe that by working with USDA to focus the program on building infrastructure and jobs between forests and facilities we can achieve the purposes of the BCAP program as outlined by Congress while providing significant benefits to rural communities that are struggling through difficult economic times.”

The manner by which USDA finalizes and implements the BCAP regulations will be critical to whether these goals ultimately are achieved.  NAFO’s recommendations for improving the CHST portion of the BCAP program focus on four general areas: (1) adhering to a broad definition of renewable biomass; (2) ensuring that an appropriate range of forest-derived biomass is eligible under the program; (3) maintaining proposed rules’ requirements for conservation plans, forest stewardship plans, or equivalent plans; and (4) guaranteeing fair treatment of applicants, in both the existing and prospective CHST program.

NAFO also recommends that the final rule should enable biomass conversion facilities to recoup certain costs associated with participating in the BCAP program, and that the final rule should not arbitrarily exclude any private forests from participating in the program.

NAFO’s full comments are available (PDF) in addition to two papers on the sustainability of private U.S. forests: NAFO’s Advocacy Position on Sustainability and Environmental Regulation of Private Forests in the U.S. and recent presentations on the carbon benefits of energy from forest biomass.

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NAFO is an organization of private forest owners committed to advancing federal policies that promote the economic and environmental values of privately-owned forests at the national level. NAFO membership encompasses more than 75 million acres of private forestland in 47 states. View NAFO’s interactive map to see the economic impact of America’s working forests.