EPA’s new rule on woody biomass will cost jobs

The U.S. Environmental Protection Agency has strayed from its core mission in favor of an aggressive agenda that often circumvents Congress, treats health as a means rather than an end and increasingly costs jobs in a tough economy.

The latest EPA overreach has Southern Missouri schools, cities and small businesses backing off plans to convert coal-fired boilers to biomass, at a 90 percent savings in emissions. A new EPA rule will not recognize woody biomass — the waste wood cleared from our plentiful forests as part of good land management or through the forest products industry — as a renewable fuel.

The consequences could be severe for the 100-job, $120 million construction of the Perryville Renewable Energy Center, a 32-megawatt project to power 23,000 homes with clean energy. Ironically, without the new plant, which is moving forward despite the ruling, these 23,000 homes would revert to coal, and a $10 million market for our state’s forestry industry would disappear.

The EPA’s twin killing would stop the development of low-emission domestic energy production in rural America and encourage the waste of forest by-products. The EPA is uninterested in innovation and practical energy solutions, unless it is windmills, solar panels or giant kites to harness high-altitude winds.

Twenty years ago, legislators could count on an earnest, if eager, regulator at the EPA. The Clean Air Act and Clean Water Act were landmark articles of legislation with apolitical intentions and limited consequences for American workers. Today, the EPA is using its authority to further a political agenda, to help liberal politicians satisfy special interests and lay the groundwork for sweeping policy change that otherwise would not survive a single administration.

The EPA has an important mandate at a time when technological developments promise a transition to cleaner energy and manufacturing with minimal costs. But a “green revolution” can be accomplished only with the cooperation of American businesses, not by overwhelming them.

U.S. Rep. Jo Ann Emerson • R-Cape Girardeau

The following members of Congress signed the letter:

TOTAL: 106
Democrats: 45
1. Altmire
2. Barrow
3. Berry
4. Sanford Bishop
5. Boren
6. Boswell
7. Boucher
8. Boyd
9. Bright
10.Butterfield
11.Carney
12.Childers
13. Dahlkemper
14.Artur Davis (AL)
15.Lincoln Davis (TN)
16.Donnelly
17.Etheridge
18.Hare
19.Alcee Hastings (FL)
20.Herseth-Sandlin
21.Holden
22.Kagen
23.Kissell
24.Lipinski
25.Jim Marshall (GA)
26.Matheson
27.Melancon
28.McIntyre
29.Michaud
30.Brad Miller (NC)
31.Minnick
32.Scott Murphy (NY)
33.Oberstar
34.Owens
35.Peterson
36.Pingree
37.Pomeroy
38.Ross
39.Schrader
40.David Scott (GA)
41.Shuler
42.Space
43.Spratt
44.Stupak
45.Tanner

Republicans: 61
1. Aderholt
2. Alexander
3. Bachus
4. Rob Bishop (UT)
5. Blackburn
6. Boehner
7. Bonner
8. Boustany
9. Kevin Brady (TX)
10.Cantor
11.Chaffetz
12.Coble
13.Geoff Davis (KY)
14. John Duncan
15.Fleming
16.Foxx
17.Gingrey
18.Gohmert
19.Goodlatte
20.Griffith
21.Guthrie
22.Ralph Hall (TX)
23.Harper
24.Doc Hastings (WA)
25.Herger
26.Walter Jones (NC)
27.LaTourette
28.Christopher Lee (NY)
29.Lummis
30.Manzullo
31.Marchant
32.McHenry
33.McMorris-Rodgers
34.Mica
35.Candice Miller (MI)
36.Jeff Miller (FL)
37.Moore-Capito
38.Tim Murphy (PA)
39.Myrick
40.Olson
41.Petri
42.Pitts
43.Platts
44.Putnam
45.Rehberg
46. Mike Rogers(AL)
47.Mike Rogers (MI)
48.Roskam
49.Rooney
50. Scalise
51.Schmidt
52.Schock
53.Shimkus
54.Shuster
55.Simpson
56.Sullivan
57.Glenn Thompson (PA)
58.Upton
59.Walden
60.Westmoreland
61.Whitfield

Appeared in print in the Register-Guard: Sunday, Aug 8, 2010

Our renewable energy plant makes financial sense because we will fuel it with residual materials created in the lumber manufacturing process. These include slash from forest harvest landing sites, and bark, sawdust and planer shavings from the milling process. This approach makes the highest and best use of each log harvested; no part of the log is wasted.

Energy prices are measured in cents, while lumber prices are stated in dollars. The two commodities are miles apart in value. That disparity will only increase in the future.

We are a local, family-owned company, and we carefully manage our lands so that we will always have logs to produce timber. Our founder, Aaron Jones, began purchasing timberlands in 1989. Today, our 165,000 acres of lands contain 78 percent more beautiful, healthy trees than they did when we purchased them.

Arkin refers to the Massachusetts Manomet Study to cast doubt on our project. The report does quite the opposite. It clarifies that “when biomass is sustainably harvested and forestlands are well managed over time, biomass can be a source of low-carbon energy, especially when compared to fossil fuel.”

Arkin mentions 500 tons of toxins, although she fails to define what she means by “toxins.” We assume she is referring to hazardous air pollutants that can be associated with certain cancers, or fine particulates that can be associated with asthma or other lung diseases.

By far, the largest emitters of HAPs in this area are vehicles and residential wood stoves. Total area HAP emissions equal 7,724 tons per year. Seneca’s permit from the Lane Regional Air Protection Agency limits our HAP emissions to less than 17 tons per year. This is a limit, and therefore is on the high end of what Seneca will emit.

By operating its biomass plant, Seneca will actually decrease the amount of HAPs it currently emits. Let me explain. Under forest protection laws, slash is required to be burned to reduce the risk of fire, insects and disease. The Environmental Protection Agency estimates that benzene emissions from the open burning of Douglas fir slash are 163 times more than when the same ton of slash is burned in our renewable energy facility. Emissions of other organic air toxics (e.g., styrene, toluene, etc.) from open slash burning are also significantly higher than from controlled combustion. Bottom line: Our reduction of slash burning is estimated to reduce total HAP emissions by more than 20 tons per year.

This does not even begin to tell the whole story. Open burning generates 672 times more greenhouse gases than controlled combustion, and 960 times more hydrocarbons. By decreasing open burning, we will significantly improve air quality.

Our plant will also create excess steam that will replace the natural gas that currently fires our kilns to dry our lumber. The renewable energy plant will provide steam for our kilns and energy for our community. This is known as cogeneration. Eliminating the use of natural gas will decrease greenhouse gas emissions by 14,000 tons per year. According to the Manomet Study, using biomass heat and cogeneration is most efficient in reducing greenhouse gas emissions over time when compared to fossil fuels.

We are spending millions of dollars to make our plant the cleanest in America. Our operations will result in a net decrease in particulate emissions of 275 tons per year, and this did not go unnoticed by the Environmental Protection Agency. Nancy Helm, manager of the EPA’s Office of Air, Waste and Toxics, writes the following in her report to LRAPA:

“EPA applauds [Seneca’s] commitment to protect air quality. Biomass boiler particulate matter emissions will be generated at a rate less than 40 percent of the emission rate permissible for recently constructed similar sources in the Pacific Northwest” (Sept. 8, 2009).

The U.S. Department of Energy has called for the doubling of electrical power generated from biomass plants. The European Union has identified biomass cogeneration as a primary means of decreasing greenhouse gas emissions.

Gov. Ted Kulongoski stated, “I am honored to support the Seneca Sustainable Energy project. This project represents an excellent example of how we get people back to work in Oregon and continue to serve as a model for the entire country of how to grow a new economy where economic prosperity is tied directly to our commitment to a sustainable future.”

Seneca’s renewable energy plant is clean and green. It makes full use of every log harvested and provides our community with a source of renewable energy.

It will be a tremendous asset to our community, now and in the future.

Rick Re is the vice president and general manager for Seneca Sawmill Company.

Watch the video and read more here.

David P. Tenny, President and CEO of NAFO, said, “EPA made some positive steps in the rule to appropriately address the combustion of biomass for energy under RCRA. The law dictates that traditional fuel sources are not considered waste, and the forest products industry began using wood and wood residuals to generate electricity and heat decades before modern solid waste regulation. Ensuring appropriate treatment of biomass under the rule will help biomass make its full contribution to our nation’s renewable energy goals.”

RCRA regulates hazardous waste and differentiates combustion between traditional uses (i.e. biomass for energy) and incineration of waste materials – the latter of which is regulated under RCRA. NAFO is concerned that the proposed rule would unnecessarily narrow the materials indentified as non-wastes under RCRA to exclude biomass.

Tenny elaborated on the effects of this, “Experience shows that facilities will simply stop burning for energy recovery those materials that EPA labels ‘wastes,’ since continuing to burn them would increase regulatory costs and create public relations challenges. There are certainly valid concerns about the need to contain emissions from the incineration of hazardous materials, but wood energy is clean, renewable, and a proven means of reducing carbon in the atmosphere.”

NAFO’s full comments are available on NAFO’s 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 75 million acres of private forestland in 47 states. View NAFO’s interactive map to see the economic impact of America’s working forests.

I couldn’t disagree more with the July 27 column by Lisa Arkin of the Oregon Toxics Alliance, “Burning biomass to generate electricity is a dirty business.”

The author plays fast and loose with the words “pollution” and “toxics,” and above all misrepresents a scientific study requested by the Massachusetts Department of Energy Resources and completed by the Manomet Study Center.

The Manomet study’s authors say that using woody biomass sustainably to produce energy does not increase carbon in the atmosphere. And it has significant carbon benefits over fossil fuels, because it recycles atmospheric carbon.

Atmospheric carbon dioxide is a necessary component of our air, because without it trees or any plants cannot grow. It is essential to plant life. The concern today is not about the toxicity of carbon dioxide, but rather whether we have too much of it from burning fossil fuels such as oil, coal and natural gas that long have been stored in our Earth’s geology.

Unlike Massachusetts, Oregon has a large forest products industry that produces a significant amount of wood waste from making the wood products used by all. A portion of the waste comes from harvest operations, and some comes from mill residues. Manufacturers building these biomass facilities help themselves and others by using woody debris responsibly.

By using woody biomass to create a new source of electricity, we supply the growing energy needs of our community with a dependable, schedulable source of renewable electricity, displacing fossil-fueled sources. Some of these biomass plants make use of the same steam energy to both dry lumber and make electricity, further reducing the need for natural gas.

Arkin unfairly suggests that businesses are itching to cut down whole, healthy trees simply to make electricity. Nobody is suggesting such a thing.

The state of Oregon also believes that forest restoration activities hold the potential to provide more biomass for renewable energy.

Sensibly sized and logically located biomass plants throughout the dry forestlands of Eastern and interior Southwest Oregon could help offset costs for forest restoration. Consensus is forming that these overstocked and often diseased and bug-infested stands could benefit from thinning to help make them fire resilient.

Like Massachusetts, Oregon also has studied biomass in context of our own state, and those published conclusions informed the state’s Biomass Working Group. Please see oregonforests .org, under the pull-down menu Facts and Resources, to see a special report titled “Woody Biomass Energy — A Renewable Resource to Help Meet Oregon’s Energy Needs.” Or download copies of the full study.

While you are there, another special report and full study titled “Forests, Carbon and Climate Change — A Synthesis of Science Findings” helps the reader understand the complex relationship between forests and carbon storage.

Biomass energy, produced in a properly sized facility, can have positive environmental benefits for Oregon.

In its final greenhouse gas Tailoring Rule, EPA unexpectedly reversed established government precedent and practice on the treatment of carbon dioxide (CO2) emissions from the combustion of biomass without providing adequate public notice and in contradiction of its own proposal. According to the Rule, EPA will count biomass CO2 emissions the same as fossil fuel emissions in permitting programs under the Clean Air Act. EPA’s proposed Tailoring Rule recommended that CO2 emissions from the combustion of biomass should not be counted, consistent with the past practice of EPA and other agencies of the federal government.

David P. Tenny, President and CEO of NAFO, said, “NAFO was compelled to file these petitions. EPA’s reversal from the proposed to the final rule was a significant step backward for renewable energy that came as a surprise without prior notice or adequate explanation in the record. If allowed to stand, this decision will cripple the biomass energy marketplace at the very moment when our nation needs additional investment to realize its renewable energy goals. It could also cause significant harm to forest owners and mills using biomass energy that, combined, form the economic and employment backbone of many rural communities.”

Tenny emphasized that the rule contradicts the EPA’s and Department of Energy’s long recognized policy 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.” Tenny said, “Regulating biomass energy the same as fossil fuels ignores the scientific fact that biomass recycles carbon in the atmosphere while fossil fuels add to it. This unprecedented shift in federal policy will prolong our dependence on carbon emitting fossil fuels. It will also add to the economic pressures forcing sustainably managed private forestland into other more economically competitive uses with far fewer GHG mitigation benefits.”

Tenny pointed to U.S. government data demonstrating that forestry in the U.S. has a long track record of sustainability with significant carbon benefits, “The United States is a world leader in sustainable forest management. As a result, our total acres of forest has been stable for over a century, and our volume of growing trees has increased by nearly 50 percent over the last 50 years. 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.”

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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.