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.

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.

View the video below and visit www.rethinkforests.com.

The letter reminds Administrator Jackson of the expected adverse effects of the Tailoring Rule and encourages the EPA to acknowledge scientific precedent and the carbon benefits of woody biomass fuels. Additionally, the letter sreminds Administrator Jackson of the June 2010 letter “expressing deep disappointment and concern over the treatment of renewable biomass in the final Tailoring Rule and request[ing] a stay of the application of the rule to biomass combustion facilities.” The new letter stresses the urgency now of staying the rule until the “supplemental rulemaking process is complete.

The December 10 letter can be read here.

More information about the expected effects of the Tailoring Rule can be found here.

The following members of Congress signed the letter:

Peter DeFazio
Greg Walden
Kurt Schrader
Cathy McMorris Rodgers
Norm dicks
Doc Hastings
Michael Michaud
Michael Simpson
David Wu
G.K. Butterfield
Rick Larsen
Sanford Bishop
Mike Ross
Jo Bonner
Ron Kind
G.T. Thompson
Wally Herger
John Sullivan
Dan Boren
Paul Broun
Jo Ann Emerson
Walter Jones
Doug Lamborn
Mike Rogers
Adam Smith
Denny Rehberg
Shelley Moore Capito
Sue Myrick
Rob Bishop
Joseph Pitts
William Owens
David Reichert
William Owens

The study, commissioned by the National Alliance of Forest Owners (NAFO) and conducted by Forisk Consulting, a nationally respected market analysis firm, provides the most recent example of the need to amend the Tailoring Rule’s treatment of woody biomass before the rule is implemented on January 2, 2011.

“The Tailoring Rule is a powerful deterrent to forest biomass energy investments and job opportunities,” NAFO President and CEO David P. Tenny said of the study’s findings. “We’re already seeing the economic impact of the Tailoring Rule, as renewable energy projects are delayed or stopped altogether due to regulatory uncertainty. Left unchanged, the Tailoring Rule threatens the long-term viability of the biomass energy sector which, in turn, undermines the renewable energy goals of the Administration and Congress.”

The study finds that the regulatory uncertainty created by the EPA has contributed to stalled investment in at least 23 near-term projects representing 1,519 megawatts of potential electrical capacity while noting that developers of a number of additional projects affected by the rule have chosen to remain anonymous.

Dr. Brooks Mendell, the lead author of the study, cited the conflict between renewable energy goals and the Tailoring Rule, “Pre-Tailoring Rule projections suggest that up to 19 states would be unable to satisfy a minimum renewable electricity standard of 15% by 2021. Taking into account impacts on investment in wood bioenergy projects, particularly in wood-rich states and regions, implementation of the Tailoring Rule could leave up to 30 states unable to meet renewable energy goals.”

The Forisk analysis complements a recent study released by scientists at the University of Washington concluding that the treatment of biomass under the Tailoring Rule will promote the continued use of fossil fuels, increase greenhouse gas emissions from national forests and jeopardize U.S. jobs in the forest products industry (see www.corrim.org/pubs/reports.asp).

It also confirms concerns raised by 113 U.S. scientists in a letter to Congress opposing the Tailoring Rule’s treatment of biomass energy because of its inconsistency with sound science and its negative impact on the development of new emission reducing biomass energy facilities (See www.nafoalliance.org/scientists).

A bipartisan group of Congressional lawmakers along with state and local political leaders across the country are urging the EPA to amend the Tailoring Rule’s treatment of woody biomass energy before the rule takes effect on January 2, 2011.

The one page summary and the full economic impact study can be found here: www.nafoalliance.org/impact-study.

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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. 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.

Forisk Consulting provides research and educational services to executives and analysts making decisions related to timber REITs, timberlands, and wood-using energy and manufacturing facilities. For more information about Forisk, visit .

Notably, the study found that with the Tailoring Rule, the EPA clearly ignores the carbon neutrality of woody biomass that has been established through past policy and scientific precedent.

The study indicates that the economic consequences of the rule would produce “substantial regulatory uncertainty and significant compliance costs” for biomass and will reduce “U.S. forest sector competitiveness even more in a time when it is already subject to extraordinary market and economic forces. The expected result will be a decrease in U.S. production.”

Conducted by researchers working with the Consortium for Research on Renewable Industrial Materials (CORRIM), the study found that the rule will encourage the use of fossil fuels.

Highlights of the findings of the study can be read here and the full study can be read here.

WASHINGTON, D.C. (December 1, 2010) — The National Alliance of Forest Owners (NAFO) today filed formal comments with the Environmental Protection Agency (EPA) on its recent guidance to states on how to implement the Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule using Best Available Control Technology (BACT). While acknowledging that EPA has moved toward recognizing the carbon benefits of utilizing forest biomass in the guidance, NAFO urged EPA to amend the Tailoring Rule to fully account for such benefits in the PSD program and to stay implementation of the Tailoring Rule while it does so.

“The guidance offers a welcome change in direction regarding how EPA views the carbon benefits of utilizing forest biomass. However, it does not alleviate the significant regulatory and permitting burdens that are hindering the development of clean energy projects utilizing biomass,” NAFO President and CEO Dave Tenny wrote in the formal comments. Tenny summarized NAFO’s concerns, “EPA’s current position deters green job creation, stalls investment in near-term projects, sets back technological advancements in renewable fuel deployment, incentivizes a conversion back to carbon-intensive fossil fuels, and discourages sustainable forest management practices. Unless changed, it is a significant hurdle to advancing a major source of renewable energy in our country.”

The EPA guidance does not amend the treatment of woody biomass in the Tailoring Rule, nor does it clarify how woody biomass will be treated as BACT. The guidance states that each state must make its own determination about whether renewable biomass could be used as a tool to fight greenhouse gas emissions. The EPA has said they will not clarify the BACT guidance until after the Tailoring Rule has been implemented in January 2011, and will not consider whether to amend the Tailoring Rule with respect to biomass emissions until May 2011.

NAFO’s comments reference recent scientific work highlighting the unintended consequences of the Tailoring Rule. A recent paper authored by noted experts at the University of Washington concludes, “Using the EPA accounting method substantially overstates biomass plant emissions. . . The result of the EPA method would penalize the larger mills and energy producers for using biofuel. This outcome is clearly counterproductive to the objective of reducing overall carbon dioxide concentrations.” The full paper is available from the Consortium for Research on Renewable Industrial Materials (CORRIM), a non-profit corporation of 17 research institutions (www.corrim.org/pubs/). Its conclusions expand on concerns raised by 113 scientists in a July letter to Congress stating that the Tailoring Rule is “not consistent with good science and. . . could also encourage existing biomass energy facilities to convert to fossil fuels or cease producing renewable energy.”

NAFO’s full comments are available at www.nafoalliance.org/tailoring-rule-bact.

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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. 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.