The U.S. Environmental Protection Agency (EPA) has an opportunity to advance the Obama Administration’s “all-of-the-above” approach to future energy needs in the U.S. Think forests and renewable energy.

The forest products industry is the leading producer and user of renewable biomass energy and produces more renewable energy from biomass than all the energy produced from solar, wind and geothermal sources combined. Biomass combustion produces enough energy to power nearly 3 million homes and should be encouraged as part of our country’s approach to reducing our reliance on fossil fuels.

But, in 2010, the EPA made a sudden shift from its past policy and announced in Clean Air Act greenhouse gas regulations, commonly known as the “Tailoring Rule,” that it would regulate biogenic carbon emissions from stationary sources in the same manner as fossil fuel emissions. This was a radical departure from how biogenic emissions had been regulated in the past both in the U.S. and the international community and ignored the scientific fact that biomass energy merely recycles carbon in the atmosphere while fossil fuels add to it.

NAFO petitioned EPA to correct this flaw. In response to NAFO’s petition, EPA sensibly deferred until 2014 its decision to regulate biogenic emissions from stationary sources and commissioned a panel under the auspices of its Science Advisory Board (SAB) to conduct a science and technical review of EPA’s Accounting Framework for Biogenic CO2 Emissions from Stationary Sources. The SAB panel reviewed the draft framework for nine months and prepared a report and recommendations for final SAB review and transmission to the EPA.

The SAB panel report confuses rather than clarifies the path forward. On the one hand, the panel finds that EPA’s draft accounting framework is seriously flawed and needlessly complex. On the other hand, the panel’s recommendations introduce so much new complexity that they would discourage the use of biomass as an alternative to fossil fuels. The SAB has provisionally approved the report and will likely deliver the final version to the EPA Administrator this fall.

Ultimately, EPA must develop an accounting framework and carbon emissions policy capable of implementation. The agency could accomplish this using readily available U.S. Forest Service (USFS) data collected for decades, rather than developing overly complex and uncertain models that attempt to predict the potential carbon impacts of biomass energy decades into the future as recommended by the SAB panel. USFS data show:

  • The U.S. grows more trees than it harvests for all purposes, including energy production. USFS reports that the standing inventory (volume of growing trees) in U.S. forests has grown by 63% between 1953 and 2011.[1]
  • Carbon storage in U.S. forests continues to increase, sequestering more than 800 million metric tons of carbon dioxide equivalents annually.[2]

The bottom line is that, so long as forest carbon stocks overall are stable or increasing as verified by ongoing data collection, renewable energy from these forests does not increase overall carbon in the atmosphere.

NAFO is urging EPA to return to where it started, and use the data it has and continues to collect to support a policy that excludes forest biomass energy emissions in its greenhouse gas regulatory program so long as forest carbon stocks in the U.S. are stable or increasing. This approach is supported by more than 100 notable scientists who have written to Congress urging the appropriate treatment of wood biomass carbon in national energy policy, stating that:

  • “…the carbon dioxide released from the combustion or decay of woody biomass is part of the global cycle of biogenic carbon and does not increase the amount of carbon in circulation…” and; “…the regeneration of the forest [where] the volume of removals [is] no greater than new growth less mortality results in stable levels of carbon in the forest and sustainable removals as a carbon neutral source for energy.”[3]
  • EPA has concluded that there is “scientific consensus … that the carbon dioxide emitted from burning biomass will not increase CO2 in the air if it is done on a sustainable basis.”[4] This position is supported by the Intergovernmental Panel on Climate Change, the Energy Information Administration, the World Resources Institute and other credible scientific bodies.

The EPA has an opportunity to reaffirm the scientifically sound and internationally accepted policy that wood biomass energy emissions do not increase CO2 in the air so long as the data show that the overall carbon in our forests remains stable. By doing so the EPA will encourage—rather than discourage—biomass as a viable renewable energy as part of an “all-of-the-above” plan for U.S. energy independence.

Dave Tenny, President and CEO


[1] U.S. Forest Information Service.
[2] EPA Inventory of Greenhouse Gas Emissions and Sinks: 1990-2010.
[3] Bruce Lippke et al., Letter to Congress (July 20, 2010).
[4] U. S. Environmental Protection Agency Combined Heat and Power Partnership. Biomass Combined Heat and Power Catalog of Technologies, 96 (Sept. 2007) available at