Thursday, August 11, 2016

Dear Fellow Scientists:

We are writing because we are concerned that a letter you sent to the U.S. Environmental Protection Agency about bioenergy is being misused by supporters of Congressional legislation that would define forest bioenergy as carbon neutral.  It is dangerous to legislate scientific “facts” that are erroneous and conflict with internationally agreed upon standards, and troubling that your statement is being misrepresented. If you share our concern, we encourage you to speak out and prevent continued efforts to miscast your views.  Though we may not agree on all issues regarding bioenergy, as scientists we share a commitment to develop policies that accurately reflect bioenergy’s costs and benefits.  The current use of your letter falls short of these standards.

In the letter you sent to EPA on November 6, 2014, it is clear that you did not make the claim that forest bioenergy is carbon neutral.

Yet U.S. Sen. Susan Collins asserts that your letter supports her amendment[1] to the recently passed Senate Energy Bill that would require the EPA and other federal agencies to establish policies that “reflect the carbon-neutrality of forest bioenergy.” (The text of the amendment is included at the end of this letter).

After scientists criticized the “carbon-neutrality” language, the Washington Post reported in February that “a spokeswoman for Collins defended the amendment, noting that an even larger group of scientists has said they support it…  ‘One hundred nationally recognized forest scientists, representing 80 universities, have written to the EPA stating the long-term carbon benefits of forest bioenergy,’ said Annie Clark, Collins’ communications director, in a statement sent to the Post. ‘This group of forestry experts weighed a comprehensive synthesis of the best peer-reviewed science and affirmed the carbon benefits of biomass.’”[2]

In April, after the amendment passed the Senate as part of the energy bill, Sen. Collins issued a news release implying that your letter supported her amendment.[3]

One of your colleagues who signed the letter, Professor James A. Allen, Executive Director of Northern Arizona University’s School of Forestry, told Wired Magazine that “I haven’t signed something in support of the Collins Amendment….I signed a cover letter that outlined general, I think uncontroversial, principles regarding carbon biomass accounting.”[4]

The National Alliance of Forest Owners, a group that lobbies for bioenergy, used your letter to rebut those who have criticized the legislation without mentioning that your letter does not endorse the idea of carbon neutrality at the heart of these measures.[5]  In a blog post, the group’s CEO Dave Tenny gave the false impression that your letter and the Congressional legislation are on the same page.

As you may know, the Collins amendment in the Senate Energy Bill was not the only effort to legislate wood-burning power plants as having zero emissions. In an article written for the New Hampshire Timberland Owners Association,[6] Tenny stated that the energy bill amendment was a good start, but that “Our next step is to use the momentum gained from this amendment to proceed with the placement of more detailed language.”  That “more detailed” language is an amendment in the House Interior Appropriations Bill that requires EPA to base policies and actions “on the principle that forest biomass emissions do not increase overall carbon dioxide accumulations in the atmosphere when USDA Forest Inventory and Analysis data show that forest carbon stocks in the U.S. are stable or increasing on a national scale.” A similar amendment in the Senate Appropriations bill uses a regional scale, rather than a national scale. These bills are attached at the end of this letter.

Under this thinking, the forest carbon sink that presently removes 11 to 15 percent of U.S. annual emissions from the atmosphere could be eliminated with zero consequences for atmospheric carbon concentrations.

Data from the Environmental Protection Agency show that biomass power plants are extremely inefficient, emitting more CO₂ than coal-fired plants or natural gas plants per megawatt-hour.[7] Thus as your letter makes clear, the question is not whether bioenergy is carbon neutral, but how to account for these emissions, and in what time-frame.  As Oregon State University forest scientists Mark Harmon and Beverly Law recently wrote[8] to members of the U.S. Senate, the idea that current forest growth rates create “headspace” for biomass extraction, and that bioenergy is carbon neutral as long as the amount of biomass harvested remains below annual growth, is invalid in that it ignores conservation of mass.

Responding to the House language, the Obama administration wrote in an official statement that it “strongly objects” to this language “which would compel EPA to disregard the scientific recommendations of its own Science Advisory Board and other technical studies.”

As the increase in southeastern forest harvesting for wood pellet exports demonstrates, any meaningful upscaling of wood-burning for electricity generation requires a similar upscaling of whole-tree harvesting for fuel.[9]  The Intergovernmental Panel on Climate Change recognizes forest cutting as a source of carbon pollution to the atmosphere, stating “The IPCC Guidelines do not automatically consider biomass … as ‘carbon neutral,’ even if the biomass is thought to be produced sustainably.”[10]  Accordingly, attempts to legislate forest bioenergy as having zero emissions directly undermine the United States’ ability to meet our commitments under the Paris climate agreement. 

Whether or not you agree with us and professors Harmon and Law on every point, we encourage you to make clear to Sen. Collins, the National Alliance of Forest Owners, and any others who are misrepresenting your views that the letter does not endorse the concept of unqualified carbon neutrality of forest bioenergy. We would like to work with you to clarify this matter so that our forests continue to function as important carbon sinks, as well as providing the many ecosystem services and benefits your letter describes that are so important to national well-being. Please let us know if you are interested in discussing this issue further.

Sincerely,

Mary S. Booth, PhD
Director, Partnership for Policy Integrity

William R. Moomaw, PhD
Co-Director of the Global Development and Environment Institute,
Tufts University

George Woodwell, PhD
Director Emeritus,
The Woods Hole Research Center

Senate Energy Bill Biomass Amendment Language
“To support the key role that forests of the US can play in addressing the energy needs of the US, the Secretary, the Secretary of Agriculture, and the Administrator of the Environmental Protection Agency shall, consistent with their missions, jointly –
ensure that the federal policy relating to forest bioenergy –
is consistent across all Federal departments and agencies; and
recognizes the full benefits of the use of forest biomass for energy, conservation, and
responsible forest management; and establish clear and simple policies for the use of forest biomass as an energy solution, including policies that –
reflect the carbon-neutrality of forest bioenergy and recognize biomass as a renewable energy source, provided the use of forest biomass for energy production does not cause conversion of forests to non-forest use;
 encourage private investment throughout the forest biomass supply chain, including in-
 working forests;
harvesting operations;
forest improvement operations;
forest bioenergy production;
wood products manufacturing;
paper manufacturing;
encourage forest management to improve forest health; and
recognize State initiatives to produce and use forest biomass.”

House Interior Appropriations Bill biomass language:
“The Administrator of the Environmental Protection Agency shall base agency policies and actions regarding air emissions from forest biomass including, but not limited to, air emissions from facilities that combust forest biomass for energy, on the principle that forest biomass emissions do not increase overall carbon dioxide accumulations in the atmosphere when USDA Forest Inventory and Analysis data show that forest carbon stocks in the U.S. are stable or increasing on a national scale, or when forest biomass is derived from mill residuals, harvest residuals or forest management activities. Such policies and actions shall not pre-empt existing authorities of States to determine how to utilize biomass as a renewable energy source and shall not inhibit States’ authority to apply the same policies to forest biomass as other renewable fuels in implementing Federal law.”

In an official statement, the Obama administration wrote that it “strongly objects” to this language “which would compel EPA to disregard the scientific recommendations of its own Science Advisory
Board and other technical studies.”

Senate Interior Appropriations Bill biomass language
CARBON EMISSIONS FROM FOREST BIOMASS
SEC. 414. (a) IN GENERAL.—For any policy, regulation, or action of the Administrator of the Environmental Protection Agency (referred to in this section as the “Administrator”) specifically relating to carbon dioxide emissions due to the combustion of forest biomass from stationary sources, the Administrator shall provide that those emissions, including forest biomass carbon dioxide emissions from a facility that combusts forest biomass for energy, do not require regulation, control, or action if—

(1) the Secretary of Agriculture (referred to in this section as the “Secretary”) determines, based on the most recent annual assessment of forest and timberland carbon stocks derived from the Forest Inventory and Analysis data of the Department of Agriculture, that timberland carbon stocks in the relevant region, as described in subsection (b), are stable or increasing as compared to the assessment of timberland carbon stocks for that region based on the relevant average timberland carbon stock assessment baseline described in subsection (c); or

(2) the forest biomass is derived from—

(A) mill product manufacturing residuals;

(B) harvest residues;

(C) biowaste (including used wood products); or

(D) forest management activities that are conducted—

(i) to increase yield; or

(ii) to maintain or enhance forest health.

(b) REGION IDENTIFICATION.—

(1) IN GENERAL.—For purposes of the annual assessment of forest and timberland carbon stocks described in subsection (a)(1), the Secretary shall identify the relevant regions as the following:

(A) NORTH REGION—The North Region shall be comprised of the States of Connecticut, Delaware, Illinois, Indiana, Iowa, Kansas, Maine, Maryland, Massachusetts, Michigan, Minnesota, Missouri, Nebraska, New Hampshire, New Jersey, New York, North Dakota, Ohio, Pennsylvania, Rhode Island, South Dakota, Vermont, West Virginia, and Wisconsin.

(B) SOUTH REGION—The South Region shall be comprised of the States of Alabama, Arkansas, Florida, Georgia, Kentucky, Louisiana, Mississippi, North Carolina, Oklahoma, South Carolina, Tennessee, Texas, and Virginia.

(C) INTERMOUNTAIN REGION—The Intermountain Region shall be comprised of the States of Arizona, Colorado, Nevada, New Mexico, Utah, and Wyoming.

(D) PACIFIC COAST AND NORTHWEST REGION.——The Pacific Coast and Northwest Region shall be comprised of California, Idaho, Montana, Oregon, and Washington.

(2) INDIVIDUAL CONSIDERATION—For purposes of the annual assessment of forest and timberland carbon stocks described in subsection (a)(1), the Secretary shall consider individually any State not described in paragraph (1).

(e) AVERAGE CARBON STOCK ASSESSMENT BASELINE—

The Administrator, in consultation with the Secretary, shall calculate the average timberland carbon stock assessment baseline referred to in subsection (a)(1)—

(1) for the period beginning on the date of enactment of this Act and ending on December 31, 2029, based on the average timberland carbon stock assessment for the years 2006 through 2015;

(2) for the period beginning on January 1, 2030, and ending on December 31, 2039, based on the average timberland carbon stock assessment for the years 2016 through 2025; and

(3) for the 10-year period beginning on January 1, 2040, and ending on December 31, 2049, and for each subsequent 10-year period, based on the average timberland carbon stock assessment for the 10-year period following the end of the previous 10-year baseline calculation.

(d) ANNUAL DETERMINATION or APPLICABILITY.—

Not less frequently than annually, the Administrator shall review the most recent annual assessment of the Secretary referred to in subsection (a)(1) to determine the applicability of subsection (a).

(e) FOREST CARBON ASSESSMENTS. —Subject to appropriations, the Secretary shall update the measurement of forest carbon stocks with plot data not less frequently than once every 5 years.