On November 26, 2008, NAFO submitted comments in response to the Environmental Protection Agency’s (EPA) Advance Notice of Proposed Rulemaking on Greenhouse Gases (ANPR). In the ANPR, EPA solicited comments from a wide range of stakeholders on how to potentially approach the regulation of greenhouse gases (GHGs) under the Clean Air Act. NAFO’s response to the ANPR makes the following key points:
- The Clean Air Act does not authorize EPA to regulate forests as a stationary source. As the ANPR recognizes, forests in the United States serve as the most significant natural means of removing carbon from the atmosphere and absorbing carbon dioxide (CO2) through photosynthesis. NAFO strongly believes that responsibly managed forests and harvested wood products have a strong role in mitigating GHG levels, and looks forward to a collaborative effort with EPA to utilize forests to mitigate climate change.
- A true comprehensive solution to global climate change should fully account for the mitigation benefits of wood biomass and should accurately apply lifecycle analysis using analytical methods that are verifiable and meet common standards for accuracy and precision. Forests and harvested wood products also have the potential to reduce atmospheric carbon dioxide by providing biomass for renewable energy such as electricity generation and transportation fuels. Wood biomass provides a feedstock option for renewable energy that has lower lifecycle CO2 emissions than fossil fuels. NAFO supports the development of cellulosic biofuels and the comparison of the net carbon footprint of such biofuels to other fuel sources using analysis based on sound science and quality data.
- The Energy Independence and Security Act (EISA) provides the relevant authority and mandates at this time to realize GHG reductions from biofuels without requiring further controls under the Clean Air Act. An additional regulatory regime under the Clean Air Act could interfere with EISA production mandates and frustrate Congressional intent.
- Any market-based GHG trading regime should take into account the prospects for generating offset credits from private forests and harvested wood products. Climate policies can be developed to acknowledge the role of responsible forest management practices to achieve further GHG reductions, allowing offset credits from forest management and harvested wood products to be generated and traded as a flexible, cost effective way for regulators and industry to achieve net GHG reductions.
NAFO’s comments in response to the ANPR emphasize our interest in working as a strong collaborative partner with policy makers in Congress and federal agencies to explore together how our nation’s private forests can play a significant role in reducing the nation’s GHG footprint.
The full comments can be viewed here (PDF).
Tags: climate
