NAFO urges science panel to reduce complexity and consider real world forest practices
WASHINGTON – Today the National Alliance of Forest Owners (NAFO) urged the EPA’s Biogenic Carbon Emissions Panel, convened to review the carbon benefits of using wood and other biomass for energy, to seek science- based approaches to accounting for biomass carbon emissions that are consistent with real-world forest practices in the U.S. NAFO’s recommendations respond to the Panel’s draft recommendations on EPA’s Accounting Framework for Biogenic CO2 Emissions from Stationary Sources.
“Our best advice to the science panel is to be practical and stay on course,” said Dave Tenny, President and CEO of NAFO. “It is critical for the panel to consider how science intersects with real-life forest management and make recommendations founded on actual rather than theoretical practices. In the end the panel’s recommendations must support a pragmatic policy that promotes rather than discourages biomass as a renewable, carbon beneficial alternative to fossil fuels.”
NAFO’s recommendations point out that, although appropriately critical of the arbitrary scale and complexity of EPA’s proposed accounting framework, the work of the panel in several instances veers off course by exploring questions that are outside the scope of its mandate or that are unnecessarily complex given the established practices of the industry.
“Although well intentioned, some of the panel’s recommendations are unreasonably complex and would be unworkable if implemented in a regulatory context,” Tenny continued. “Understanding carbon changes in small forest stands, the slight differences between various types of forest biomass or the means to track biomass to its source may have theoretical value in certain contexts, but is ill-suited for a policy applied in a pragmatic way across a broad sector of the national economy and across forest landscapes.”
“The better approach is to take a step back, look at the forest carbon cycle at an appropriately broad scale, and identify approaches that reflect carbon changes across forest landscapes over long periods of time. If approached in this way, the inevitable conclusion is that biomass emissions do not increase net carbon in the atmosphere, unlike one-way carbon transmissions from fossil fuels, and should therefore not be regulated like fossil fuels.“
Read NAFO’s comments on the draft recommendations and statement to the science review panel, as well as and a new primer from Dovetail Partners on forest carbon.
The Biogenic Carbon Emissions Panel was established by the EPA to conduct a science and technical review of carbon emissions from biogenic energy sources. The Panel held its first meeting to accept public comments today, and will conduct a series of additional public meetings over the next several months to develop its report. The Panel’s final report will be transmitted to the EPA Administrator following review by the full Science Advisory Board.
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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 79 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.
