In response to the filing, BTEC’s Acting Executive Director Joseph Seymour stated:   “BTEC strongly supports EPA’s thoughtful, measured approach to evaluating carbon emissions from biomass energy sources.   Biomass is a renewable, carbon sequestering resource and, as such, needs to be clearly distinguished from fossil fuels in our nation’s clean air regulatory programs.”  Seymour also emphasized the considerable benefits of biomass thermal energy.  “Capturing and utilizing the heat from biomass combustion is, by far, the most efficient use of the resource.  What’s more, thermal energy from this domestic resource can be used to heat and cool entire cities and towns, providing local jobs and utilizing locally grown, sustainable biomass feedstocks.”

Seymour concluded:  “Using the legal system as a way to dismiss EPA’s review creates further uncertainty in the industry and threatens the potential capacity of biomass in contributing to our nation’s renewable energy goals.”

Read the full statement here.

WASHINGTON, DC (August 15, 2011) – The National Alliance of Forest Owners (NAFO) commented on a lawsuit filed today by the Center for Biological Diversity and others in the U.S. Circuit Court of Appeals for the District of Columbia. The lawsuit seeks to roll back the EPA’s science and policy review of the regulation of biomass energy carbon emissions.

NAFO supports the EPA’s scientific and policy review and the three-year deferral of regulating biomass carbon emissions under the Clean Air Act to allow time for the review. David P. Tenny, President and CEO of NAFO, said, “Biomass carbon emissions are fundamentally different than fossil fuels emissions, and EPA policy should reflect that scientific fact. That is why NAFO supports EPA’s decision to take a step back from treating the two identically and conduct a science and technical review. We will support EPA against an attempt to undermine this process, because it is the right thing to do.”

Tenny emphasized that, while NAFO supports the scientific and policy review by EPA, it is important that, “the EPA and other key agencies, like the Department of Agriculture and the Department of Energy, work together on a review free of arbitrary assumptions or parameters that could distort well-settled science. For instance, the review should recognize the well-established scientific fact that the forest carbon cycle is a dynamic, ongoing process occurring across broad landscapes with no specific start or end date. Arbitrarily limiting areas and timeframes when accounting for biomass carbon emissions, as some have tried to do, inevitably skews the forest carbon picture.”

For more information on renewable biomass energy from wood, visit www.renewablebiomass.org.

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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 80 million acres of private forestland in 47 states. Private, working forests in the U.S. support 2.5 million jobs. View NAFO’s interactive map to see the economic impact of America’s working forests.

NAFO participated in the Roadmap process and supports the principles outlined and agreed to in the final document. You can read the document here (PDF).

WASHINGTON – The National Alliance of Forest Owners (NAFO) supports the final U.S. Environmental Protection Agency (EPA) rule to defer the regulation of greenhouse gas (GHG) emissions from biomass for three years while the agency studies the science and policy of regulating biomass energy the same as fossil fuels.

David P. Tenny, President and CEO of NAFO, stated, “Forest owners are pleased that the EPA has finalized this rule. The final Tailoring Rule was flawed by treating biomass carbon emissions the same as fossil fuels. This is a prudent step towards restoring the federal government’s long-standing policy that biomass energy is an environmentally beneficial alternative to fossil fuels and does not increase the amount of carbon in the atmosphere.

“As the scientific and policy review commences, it is important that the EPA and other key agencies, like the Department of Agriculture and the Department of Energy, conduct a review free of arbitrary assumptions or parameters that skew well-settled science. For instance, the review should recognize that the forest carbon cycle is a dynamic, ongoing process that occurs across broad landscapes without a specific start and end date. Arbitrarily limiting areas and timeframes when accounting for biomass carbon emissions inevitably skews the forest carbon picture.

“NAFO is committed to working with the EPA and other key agencies to develop a policy accurately reflecting the science of working forests that helps meet our nation’s renewable energy goals and reduces carbon emissions.”

NAFO submitted extensive comments to the EPA’s Call for Information and on the proposed Deferral Rule. NAFO’s full comments are available at www.nafoalliance.org.

NAFO’s comments to the EPA provide answers with supporting science to the policy questions the EPA must answer, including:

• Forest carbon is most accurately measured on a national scale over a continuous timeframe rather than applying arbitrary time and space limitations on carbon measurement
• Because forests remove more carbon from the atmosphere than they release through natural and human activities, biomass energy emissions don’t increase carbon in the atmosphere and should be excluded from GHG regulations for stationary sources
• EPA should not impose a regulatory “baseline” or “business-as-usual” requirement on forest carbon that would compel forest owners to continually increase the carbon stored in individual forest tracts.

A new policy must be in place before the rule’s three year sunset or biomass energy will once again be regulated the same as fossil fuels.

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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 80 million acres of private forestland in 47 states. Private, working forests in the U.S. support 2.5 million jobs. View NAFO’s interactive map to see the economic impact of America’s working forests.

David P. Tenny, President and CEO of NAFO, underscored the importance of taking this time to conduct an independent, comprehensive review of the science and policy, “This week, Massachusetts issued proposed regulations that effectively shut the door on renewable biomass energy in that state. This appears to be what officials wanted when they initiated a study on biomass energy that limited the area and timeframe considered in a way that significantly skewed the outcome. The flawed study resulted in a flawed policy. EPA can learn from the unfortunate outcome in Massachusetts to put in place an even-handed review.”

Tenny noted that EPA’s review is more a question of policy than science, “The science is really a settled question – the cycle of biogenic carbon is biology 101. Carbon released from biomass energy is replaced in real time through continued forest growth without increasing overall carbon in the atmosphere. The question EPA must answer is how policy can best apply this science to meet our renewable energy needs and reduce unrecyclable fossil fuel carbon emissions. Unlike Massachusetts, we are hopeful that EPA will conduct a review of policy options free of arbitrary assumptions or parameters that skew well settled science.”

NAFO’s comments to the EPA provide answers with supporting science to the policy questions EPA must answer:

• Forest carbon is most accurately measured on a national scale over a continuous timeframe rather than applying arbitrary time and space limitations on carbon measurement
• Because forests remove more carbon from the atmosphere than they release through natural and human activities, biomass energy emissions don’t increase carbon in the atmosphere and should be excluded from GHG regulations for stationary sources
• EPA should not impose a regulatory “baseline” or “business-as-usual” requirement on forest carbon that would compel forest owners to continually increase the carbon stored in individual forest tracts.

Tenny reminded the EPA that NAFO, “stands ready to work with the Agency to establish a policy recognizing the full carbon and landscape benefits of forest biomass as an energy source.”

NAFO’s comments were submitted as part of the public comments for the proposed rule entitled, “Deferral for CO2 emissions from Bioenergy and Other Biogenic Sources under the Prevention of Significant Deterioration and Title V Programs.” NAFO full comments on this rule and the Call for Information are available on their website.

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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 79 million acres of private forestland in 47 states. Private, working forests in the U.S. support 2.5 million jobs. 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 (NAFO), testified today in support of EPA’s proposed rule to defer regulation of biomass carbon emissions for three years and urged the agency to act promptly to fully recognize biomass carbon benefits in its forthcoming science and policy review to bring the agency in line with Administration policy. Tenny delivered his remarks at the EPA’s public hearing in Washington, DC.

Tenny said, “President Obama has stated that biomass energy is an important part of his renewable energy agenda. EPA must act decisively and quickly to come into alignment with this policy direction.” Tenny reminded EPA that NAFO, “stands ready to work with the Agency to establish a policy recognizing the full carbon benefits of forest biomass as an energy source,” and made the following points to guide policy development for renewable biomass energy:

• Forest carbon accounting systems are policy determinations, not scientific conclusions, and should be used to achieve practical policy outcomes.
• The EPA should measure forest carbon change at the national scale. The forest carbon cycle is dynamic, global, and ongoing. Restricting forest carbon accounting to local areas or specific timeframes places arbitrary limits on forest carbon that distort the forest carbon picture.
• The EPA must recognize the prevailing scientific conclusion that the forest carbon cycle is continuous and has no “beginning.” The “carbon debt” model of carbon accounting is arbitrary on its face for two reasons – it ignores the carbon removed from the atmosphere prior to harvest, and it ignores that the harvested stand is merely one small part of the total forested landscape that removes carbon from the atmosphere before, during, and after the time of harvest.
• The EPA must avoid establishing arbitrary baselines, such as “business as usual,” to account for carbon emissions from biomass. Current forest practices yield significant carbon benefits that private forest owners provide without compensation. A “business as usual” baseline would arbitrarily “take” these benefits and introduce additional costs to forest management. Rather than promoting forest conservation, the loss in value of forest land would create additional economic incentive to convert forests to other uses.
• The EPA must recognize that all parts of the tree are part of the same carbon cycle, so net forest carbon flux should be measured across the forest, not for specific product streams. Separate carbon measurements for different feedstocks will yield arbitrary results that confuse rather than clarify the nature of the forest carbon cycle. While an important market, biomass energy produces some of the lowest returns in the forest products value chain. Consequently, there is little risk that forest owners will divert trees used for building materials and other high value products to low value biomass.

Mr. Tenny’s prepared remarks are available here.

For more information, including NAFO’s extensive response to EPA’s Call for Information, the economic impact of the Tailoring Rule’s treatment of biomass energy, and a scientific white paper on the unintended consequences of regulating biomass the same as fossil fuels, please visit www.renewablebiomass.org.

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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 79 million acres of private forestland in 47 states. Private, working forests in the U.S. support 2.5 million jobs. View NAFO’s interactive map to see the economic impact of America’s working forests.

NAFO informed the EPA that 1) the scope of NSPS does not permit EPA to regulate biomass emissions, 2) regulating biomass emissions under NSPS would undermine the EPA’s approach under the PSD programs, and 3) EPA should use private forests as an cost-effective source of carbon offsets under the NSPS program.

David P. Tenny, President and CEO of NAFO, said, “EPA must stay the course it committed to in January when Administrator Jackson decided to defer regulating biomass emissions under the PSD Tailoring Rule for three years pending further science and policy review. During this review process EPA must be consistent in its approach to biomass across all Clean Air Act programs.”

In announcing the deferral in January, Administrator Jackson said, “[r]enewable, homegrown power sources are essential to our energy future, and an important step to cutting the pollution responsible for climate change.” Secretary of Agriculture Vilsack added, “Homegrown energy can provide jobs in rural America while reducing greenhouse gases.”

NAFO agrees that biomass energy is a sustainable, renewable and carbon beneficial source of homegrown energy that supports jobs in rural communities. The science distinguishing biomass from fossil fuels is the focus of a letter to Congress from 113 highly regarded scientists stating that, “. . . equating biogenic carbon emissions with fossil fuel emissions, such as contemplated in the EPA Tailoring Rule and other policies, is not consistent with good science.” Biomass energy also provides jobs for forest owners, loggers, haulers, energy producers and others in some of our hardest hit rural economies.

EPA must keep the commitment it made under the Tailoring Rule

Tenny further urged EPA to use private forests for carbon offsets under the NSPS program, “NSPS provides an opportunity for EPA to use the unparalleled ability of private forests to remove carbon from the atmosphere as a cost effective source of offsets for fossil fuel emissions. EPA recognizes the flexibility in the NSPS to use market-based approaches, like offsets as an alternative to strict regulatory approaches. Offsets would reduce costs, making electricity more affordable, and provide much needed jobs and income to rural Americans who participate in providing offsets.”

To learn more about why biomass energy from wood is renewable, sustainable, and carbon beneficial, visit www.renewablebiomass.org. The site slices through the rhetoric and hyperbole in the dialogue and offers credible, scientific information.

WASHINGTON, DC (March 14, 2011) — The National Alliance of Forest Owners (NAFO) announced the availability of a website dedicated to offering information to inform the national dialogue on renewable biomass energy from wood. The site slices through the rhetoric and hyperbole in the discussion on biomass energy by offering credible information so policy makers can make an informed decision about our energy future.

The site, available at www.renewablebiomass.org, contains:

• Research and white papers on biomass supply, demand, greenhouse gas benefits, and more.
• Answers to frequently asked questions, such as:
  

  • Why won’t forest owners use whole forests or large, healthy trees for bioenergy?
  • Why do we need forest biomass in addition to other renewable sources, such as wind and solar?
  • Why is forest biomass energy sustainable?
  • Why is forest biomass energy beneficial to the atmosphere?

• A blog on forest biomass energy
• Tools for citizens to take action

Media Availability: NAFO President and CEO, David P. Tenny, is available to discuss renewable biomass energy from a forest landowner perspective. To request an interview, please contact Dan Whiting at (202) 747-0746 or dwhiting@nafoalliance.org.

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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 79 million acres of private forestland in 47 states. Private, working forests in the U.S. support 2.5 million jobs. View NAFO’s interactive map to see the economic impact of America’s working forests.

WASHINGTON, D.C. (March 9, 2011) — Today the National Alliance of Forest Owners (NAFO) told the House Committee on Oversight and Regulation, Subcommittee on Regulatory Affairs that changes in several EPA regulations could shift the economics of private forestry in the U.S., pushing more land into non-forest uses and costing U.S. jobs.

David P. Tenny, President and CEO of NAFO, informed the Subcommittee that laws, regulations, and policies that work with rather than against the marketplace have made the U.S. a world leader in sustainable forest management, by protecting rivers and streams, promoting forest growth, and providing homes and products to American families, “Private forests in the U.S. provide over 2.5 million jobs and $87 billion in wages to American families. They are also recognized as the most sustainable forests in the world. This is due to the effective relationship between markets that make forest ownership economical and a carefully tailored legal and policy framework. Layering on duplicative and unnecessary regulations upsets this balance and threatens the economic viability of forest ownership, placing at risk rural jobs and the environmental and the many public benefits private forests provide. Pushed too hard, ill-advised regulation can force forestland into other land uses that prove to be more economically valuable.”

Tenny stressed that private forests serve as the nation’s filter for air quality and should be supported by federal policies under the Clean Air Act, “EPA’s greenhouse gas regulations must recognize that forest biomass used for energy recycles carbon from the atmosphere through tree growth and reduces overall carbon in the atmosphere.”

Tenny further emphasized that forests protect water quality under carefully tailored Clean Water Act policies, “State administered best management practices (BMPs) have been a national success story for improving water quality. The EPA should support existing policies and avoid adding new and unnecessary permitting and paperwork costs with no corresponding environmental benefit.”

Several proposed EPA regulations and recent court decisions threaten private forestlands and the jobs they support. Tenny singled out:

• Renewable energy, an important market for forest biomass. EPA’s proposal to regulate biomass energy carbon emissions the same as fossil fuels threatens the future of this renewable energy source. Tenny urged Congress to hold the EPA to its promise to defer the regulation of biomass energy carbon emissions for three years and conduct an unbiased study of biomass carbon emissions.
• Pesticide application, a limited but important forestry tool. The EPA has effectively regulated pesticide application under the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), which requires safe pesticide application to protect people, wildlife, and water quality. Because of a court decision, EPA is in the process of adding new overlapping regulations under the Clean Water Act – a duplicative and unnecessary requirement that is confusing, costly and ultimately harmful to good forest stewardship. Tenny urged Congress to support H.R. 872 to affirm the original intent of Congress that pesticide application is best regulated under FIFRA and does not need additional and redundant regulation under other laws.
• Forest roads, the vital infrastructure for forest management and recreational access. Private and public forest managers depend on well maintained roads to harvest, replant and manage forests while also providing public recreation access. A recent decision by the Ninth Circuit U.S. Court of Appeals changed the decades-long policy of EPA that forest roads maintained to meet state water quality best management practices (BMP)s under the Clean Water Act, will also require federal permits typically required for factories and other confined industrial sites. The Ninth Circuit is currently reviewing the case en banc. Tenny asked Congress to be prepared to take legislative action, if necessary, to affirm the EPA’s long-standing policy.

For more information on these issues, please read NAFO’s fact sheets on biomass energy, forest roads, pesticide applications, and a white paper on the existing framework of laws, regulations, agreements, and non-regulatory policies that govern private forestry in the U.S.

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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 79 million acres of private forestland in 47 states. Private, working forests in the U.S. support 2.5 million jobs. View NAFO’s interactive map to see the economic impact of America’s working forests.