Pasted below is a letter from 91 scientists in the US to their Environmental Protection Authority urging it to heed the input from its own science advisors that there is no scientific justification for accepting the biomass energy industry’s often repeated assertion that just because trees and other biomass regrow, all biomass energy should automatically be considered “carbon neutral”. The latest and best science tells us just the opposite: that not all biomass is made equal. In particular, chipping up and burning whole trees for electricity actually increases carbon emissions for decades compared to fossil fuels like coal. Read on: June 19, 2014 Sent via First Class Mail and E-mail Mr. Joe Goffman Senior Counsel, Office of Air and Radiation U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, N.W. Mail Code: 6101A Washington, DC 20460 Dear Mr. Goffmam: We, the undersigned scientists, believe regulations governing how stationary sources account for biogenic carbon emissions must be based on sound science and ensure adequate protections for forests and the climate. We applaud the EPA for setting a high standard in making policy on this important issue by seeking expert scientific input from the Science Advisory Board (SAB). We now urge the agency to follow through on that process and embrace the central scientific principles underscored by the SAB as you finalize these accounting rules. Doing otherwise at this juncture will fail the test of rigorous, science-based policymaking and could result in regulations that distort the marketplace towards greater use of unsustainable sources of biomass, with significant risks to our climate, forests and the valuable ecosystem services they provide and we rely on. In 2011, EPA initiated a science-driven process to develop a methodology for properly quantifying biogenic carbon emissions from stationary sources under the Clean Air Act. As part of this process, the agency rightly solicited scientific input by submitting a draft “Accounting Framework for Biogenic CO2 Emissions from Stationary Sources” to the SAB for review by an assembled Biogenic Carbon Emissions Panel. As EPA now finalizes its biogenic carbon accounting rules, it must follow through on that process and adopt the science panel’s key recommendations: 1) moving beyond the flawed assumption that bioenergy is inherently carbon neutral; 2) rejecting the regional accounting method originally proposed in the draft Accounting Framework; and 3) ensuring a scientifically sound methodology for determining the carbon emissions impact to the atmosphere from burning long-recovery woody biomass feedstocks—most notably, whole trees. First, the carbon dioxide (CO2) emitted by biomass-fired stationary sources has often been ignored in regulatory contexts, usually on the assumption that biomass regrowth would quickly reabsorb the CO2 emitted by the facilities. As the EPA has itself determined, that assumption is misguided. The SAB issued a clear rejection of an a priori assumption of carbon neutrality as it applies to bioenergy. This includes repeated reference in the panel’s report to the considerable heterogeneity in biomass feedstock types, sources, and bioenergy production methods and thus net biogenic carbon emissions impacts, and insistence on the need to define carbon outcomes based on “what the atmosphere sees” (see endnote).i The SAB’s findings are both informed by and echo recent advances in science and accounting for CO2 emissions from different woody biomass types, which have clarified that burning trees to produce electricity increases carbon emissions and contributes to other air pollution problems.ii While there is some variability in results due to differences in climate and forest type, as well as biomass plant conversion efficiency and the carbon density of displaced fossil fuels, studies conducted in different regions of the U.S. have found that burning whole trees in conventional, standalone power plants increases carbon emissions relative to fossil fuels for 35 to 100 years or more. These studies are part of a growing body of science on the lifecycle impacts of biomass that points to the need to distinguish amongst types of biomass.iii Second, U.S. forests currently serve as a net carbon sink, offsetting a significant amount of U.S. carbon emissions. This is often cited as justification for claims about carbon benefits associated with burning wood pellets made from U.S. forests. However, taking credit for forest growth and carbon sequestration that would be happening anyway would represent a major carbon accounting error since diminishing a carbon sink is the same as increasing carbon emissions from the perspective of the atmosphere. Consequently, a power plant that burns trees cannot be given credit for forest growth and carbon sequestration that would be happening anyway. Only when bioenergy results in additional carbon being sequestered above and beyond the anticipated baseline (the “business as usual” trajectory) can there be a justification for concluding that such energy use results in little or no increase in carbon emissions. The SAB issued a strong critique of EPA’s proposal in its Draft Framework to set baselines based upon land-based carbon stocks at the regional level. The panel concluded that this approach is scientifically unjustified and fails to capture the causal connection between woody biomass harvesting and atmospheric impacts.1 Further, the SAB concluded that such an approach is likely to create perverse incentives for investors and land-owners and result in unintended consequences—and, conversely, discourage the use of biomass that compares favorably to fossil fuels in terms of GHG emissions.2 Finally, for long recovery woody biomass feedstocks such as roundwood, the SAB underscored the need to model a “business as usual” scenario projected into the future (“anticipated future” baseline) as the sole means by which to give credit for only additional carbon sequestration.3 As the SAB’s final report states, “although any ‘business as usual’ projection would be uncertain, it is the only means by which to gauge the incremental impact of woody biomass harvesting.”iv In other words, it is the lone way to ensure that only carbon reductions above and beyond what would have happened anyway are credited against smokestack emissions under EPA’s biogenic carbon accounting framework. 1 “The use of unspecified “regions” as fuelsheds in combination with a reference year baseline is a central weakness of the Framework with respect to forest-derived feedstocks…[This approach] decouples the BAF from a particular facility’s biogenic emissions and the sequestration (offset) associated with its particular feedstock. Emissions from a stationary facility would be included or excluded from greenhouse gas regulation depending on a host of factors in the region far beyond the facility’s control…As a result, the Framework fails to capture the causal connection between forest biomass growth and harvesting and atmospheric impacts and thus may incorrectly assess net CO2 emissions of a facility’s use of a biogenic feedstock (SAB 9-28-12, pgs. 2, 5-6).” 2 “The proposed Framework is likely to create perverse incentives for investors and land-owners and result in unintended consequences …The designation of regions … that comes from the reference year approach will create economic rents and therefore financial stakes in the determination of regions and management of forests in those regions (SAB 9-28-12, pg.36).” 3 [For forest-derived woody biomass]… the Framework would need to model a “business as usual” scenario along some time scale and compare that carbon trajectory with a scenario of increased demand for biomass…An anticipated baseline requires selecting a time period and determining what would have happened anyway without the harvesting and comparing that impact with the carbon trajectory associated with harvesting of biomass for bioenergy. Although any “business as usual” projection would be uncertain, it is the only means by which to gauge the incremental impact of woody biomass harvesting (SAB 9-28-12, pg.5).” 3 We share the SAB’s very serious reservations about the accounting methodology that the EPA proposed in its Draft Framework. Instead of allowing polluting facilities to ‘free ride’ on existing forest growth in their regions, we urge EPA to follow the science by putting in place a system that links emitter behavior directly to what’s happening on the landscape and rigorously assesses the incremental carbon emissions impacts of bioenergy production. We believe this is the only way to create the necessary market incentives to encourage bioenergy facilities to source low-carbon biomass resources, efficiently burn or otherwise convert them to electricity, and to use the electricity and heat in the applications that most effectively reduce net GHG emissions. Thank you for your consideration of this request, and please do not hesitate to contact us if you would like more information and/or to discuss these issues further. Sincerely, Viney P. Aneja, Ph.D., Professor, Department of Marine, Earth, and Atmospheric Sciences, North Carolina State University, Raleigh, NC Mark S. Ashton, Morris K. Jessup Professor of Silviculture and Forest Ecology Yale University, New Haven, CT Mary S. Booth, Ph.D., Director, Partnership for Policy Integrity Mark A. Bradford, Ph.D., Assistant Professor of Terrestrial Ecosystem Ecology, Yale School of Forestry and Environmental Studies, New Haven, CT Robert Cabin, Ph.D., Professor of Ecology, Brevard College, Brevard, NC Ray Callaway, Professor, The University of Montana Eric Chivian M.D., Founder and Director Emeritus, Center for Health and the Global Environment, Harvard Medical School, Cambridge, MA Norm Christensen, Ph.D., Professor (Emeritus), Nicholas School of the Environment, Duke University, Durham, NC James S. Clark, Ph.D., Blomquist Professor, Nicholas School of the Environment, Duke University, Durham, NC Scott L Collins, Regents Professor of Biology, Loren Potter Chair of Plant Ecology, University of New Mexico, Albuquerque, NM Jeffrey Corbin, Ph.D., Associate Professor, Biology Department, Union College, Schenectady, NY Peter Crane, Ph.D., Carl W. Knobloch, Jr. Dean of the School of Forestry & Environmental Studies and Professor of Botany, Yale University, New Haven, CT Gretchen Daily, Ph.D., Bing Professor of Environmental Science, Department of Biology and Woods Institute, Stanford University, Stanford, CA 4 Eric A. Davidson, Ph.D., Adjunct Senior Scientist, Woods Hole Research Center, Woods Hole, MA Saara J. DeWalt, Ph.D., Associate Professor of Biological Sciences, Clemson University, Clemson, SC Jeffrey S. Dukes, Professor, Department of Forestry and Natural Resources & Department of Biological Sciences, Purdue University, West Lafayette, IN Jonathan Evans, Assistant Provost for Environmental Stewardship and Sustainability, Professor of Biology, Sewanee: The University of the South John J. Ewel, Ph.D., Professor Emeritus, University of Florida, Gainesville, FL; and former Director, U.S. Forest Service, Institute of Pacific Islands Forestry Tim Fahey, Ph.D., Liberty Hyde Bailey Professor, Department of Natural Resources, Cornell University, Ithaca, NY Ivan J. Fernandez, Ph.D., Professor, School of Forest Resources and Climate Change Institute, University of Maine, Orono, ME Adrien Finzi, Professor of Biology, Director, PhD Program in Terrestrial Biogeoscience, Boston University, Boston, MA Paul Fonteyn, Ph.D., President, Green Mountain College, Poultney, VT David R. Foster, Ph.D., Director, Harvard Forest, Harvard University, Petersham, MA Janet Franklin, Professor, School of Geographical Sciences & Urban Planning, Arizona State University, Tempe, AZ Scott B. Franklin, School of Biological Sciences, University of Northern Colorado, Greeley, CO Andrew Friedland, Ph. D., Professor, Environmental Studies Department, Dartmouth College, Hanover, NH Dr. Mark Fulton, Professor of Biology, Bemidji State University, Bemidji, MN James N. Galloway, Ph.D., Sidman P. Poole Professor, Department of Environmental Sciences, University of Virginia, Charlottesville, VA Andrew George, Ph.D., Adjunct Faculty, University of North Carolina, Chapel Hill, NC David J. Gibson, Ph.D., University Distinguished Professor, Department of Plant Biology, Center for Ecology, Southern Illinois University, Carbondale, IL Christine L. Goodale, Ph.D., Associate Professor of Ecology and Evolutionary Biology, Cornell University, Ithaca, NY Dr. Stith T. Gower, Director of UW-Madison BioHouse, Professor of Forest Ecosystem Ecology, Dept. of Forest & Wildlife Ecology, University of Wisconsin, Madison, WI 5 Kevin Griffin, Professor, Earth and Environmental Sciences, Biology and Paleo Environment, Lamont-Doherty Earth Observatory, Columbia University Earth Institute, Palisades, NY Bronson W. Griscom, Ph.D., Director of Forest Carbon Science, The Nature Conservancy Peter Groffman, Ph.D., Microbial Ecologist, Cary Institute of Ecosystem Studies, Millbrook, NY Jessica Gurevitch, Professor, Stony Brook University, Stony Brook, NY Charles B. Halpern, Research Professor, School of Environmental and Forest Sciences, University of Washington, Seattle, WA Mark Harmon, Ph.D., Professor, School of Forestry, Oregon State University, Corvallis, OR John Harte, Ph.D., Professor of Ecosystem Sciences, University of California, Berkeley, CA Kirsten Hofmockel, PhD., Assistant Professor of Ecology, Iowa State University, Ames, IA Richard A. Houghton, Acting President & Senior Scientist, Woods Hole Research Center, Falmouth, MA Robert W. Howarth, Ph.D., David R. Atkinson Professor of Ecology and Environmental Biology, Cornell University; Founding Editor, Biogeochemistry, Ithaca, NY Allen Hurlbert, Assistant Professor, Department of Biology, University of North Carolina, Chapel Hill, NC Michael Huston, Professor, Department of Biology, Texas State University, San Marcos, Texas Kalan Ickes, MBA, PhD, Assistant Professor, Biological Sciences, Clemson University, Clemson, SC Daniel M. Kammen, Ph.D., Class of 1935 Distinguished Professor of Energy, University of California, Berkeley, CA William Keeton, Ph.D., Professor of Forest Ecology and Forestry, Rubenstein School of Environment and Natural Resources, University of Vermont, Burlington, VT Dennis H. Knight, Ph.D., Professor (Emeritus), Department of Botany, University of Wyoming, Laramie, WY Dr. Beverly Law, Ph.D., Professor Global Change Biology, Oregon State University Deborah Lawrence, Ph.D., Professor and Director of the Program in Environmental and Biological Conservation, Environmental Sciences Department, University of Virginia, Charlottesville, VA John Lichter, Ph.D., Director of Environmental Studies, Bowdoin College, Brunswick, ME Gene E. Likens, Ph.D., Special Advisor to President on Environmental Affairs and Distinguished Research Professor, University of Connecticut; Founding Director and President Emeritus, Distinguished Senior Scientist Emeritus, Cary Institute of Ecosystem Studies, Millbrook, NY 6 Thomas Lovejoy, Ph.D., University Professor of Environmental Science and Policy, George Mason University, Fairfax, VA Jerry Melillo, Ph.D., Senior Scientist, The Ecosystems Center, Marine Biological Lab, Woods Hole, MA Myron J. Mitchell, Ph.D., Distinguished Professor and Director of Council on Hydrologic Systems Science, SUNY-College of Environmental Science and Forestry, Syracuse, NY David J. Mladenoff, Ph.D., Professor of Forest Ecology, Department of Forest & Wildlife Ecology, University of Wisconsin Jacqueline Mohan, Ph.D., Assistant Professor, Odum School of Ecology, University of Georgia, Athens, GA Russell Monson, Professor, University of Arizona, Tuscon, AZ William Moomaw, Ph.D., Professor of International Environmental Policy, The Fletcher School, Tufts University, Medford, MA Erik T. Nilsen, Professor of Biology, Virginia Polytechnic Institute and State University, Blacksburg, VA Reed Noss, Ph.D., Biology Department, University of Central Florida, Orlando, FL Michael W. Palmer, Regents Professor, Department of Botany, Oklahoma State University, Stillwater, OK Sam Pearsall, Ph.D., Adjunct in Geography & Ecology, University of North Carolina at Chapel Hill, Chapel Hill, NC Robert K. Peet, Professor of Biology, University of North Carolina at Chapel Hill, Chapel Hill, NC James Petranka, Ph.D., Professor of Biology, University of North Carolina, Asheville, NC Richard P. Phillips, Ph.D., Assistant Professor of Ecosystem Ecology, Department of Biology, Indiana University, Bloomington, IN Stuart Pimm, Ph.D., Doris Duke Professor of Conservation Ecology in the Nicholas School of the Environment and Earth Sciences Dr. Bill Platt, Professor of Ecology, Dept. of Biological Sciences, Louisiana State University, Baton Rouge, LA William A. Reiners, Professor (Emeritus), Ecosystem Ecology, Department of Botany, University of Wyoming, Laramie, WY Jim Reynolds, Ph.D., Professor of Geology, Brevard College, Brevard, NC David W. Roberts, Professor and Head, Ecology Department, Montana State University, Bozeman, MT G. Philip Robertson, Ph. D., University Distinguished Professor, Dept. of Plant, Soil and Microbial Sciences, Michigan State University, East Lansing, MI 7 Tom Rooney, Ph.D., Associate Professor, Department of Biological Sciences, Wright State University, Dayton, OH Karina V.R. Schäfer, Ph.D., Assistant Professor, Ecosystem Ecologist, Department of Biological Sciences, Rutgers University, Newark, NJ Josh Schimel, Ph.D., Professor, Department of Ecology, Evolution, and Marine Biology, University of California, Santa Barbara William H. Schlesinger, Ph.D., President, Biogeochemist, Cary Institute of Ecosystem Studies, Millbrook, NY H.H. Shugart, Ph.D., W.W. Corcoran Professor of Natural History, Department of Environmental Sciences, University of Virginia, Charlottesville, VA Miles R. Silman, Ph.D., Professor of Biology and Director, Center for Energy, Environment, and Sustainability, Department of Biology, Wake Forest University, Winston-Salem, NC Daniel Simberloff, Nancy Gore Hunger Professor of Environmental Studies, University of Tennessee James Strittholt, Ph.D., Executive Director, Conservation Biology Institute, Corvallis, OR Paula Swedeen, Ph.D., Forest Ecosystem Services Consultant, Olympia, WA Richard B. Thomas, Ph.D., Professor and Chair of Biology, West Virginia University, Morgantown, WV Alan Townsend, Ph.D., Professor, Ecology & Evolutionary Biology, University of Colorado, Boulder CO Dirk Vanderklein, Ph.D., Department of Biology and Molecular Biology, Montclair State University, Montclair, NJ Peter Vitousek, Professor of Biology, Stanford University Don Waller, John T. Curtis Professor of Botany and Chair: Department of Botany, University of Wisconsin – Madison, Madison, WI, Science Advisory Committee, Environmental Law & Policy Center Joy Kirsten Ward, Associate Professor of Biology, University of Kansas Richard Waring, Ph.D., Professor (Emeritus), School of Forestry, Oregon State University, Corvallis, OR Alan Weakley, Ph.D., Director and Curator of the University of North Carolina Herbarium, Chapel Hill, NC Kerry D. Woods, Ph.D., Professor of Natural Sciences, Bennington College, Bennington VT Robert S. Young, Ph.D., Director, Program for the Study of Developed Shorelines, Western Carolina University, Cullowhee, NC cc: Sarah W. Dunham, EPA Office of Atmospheric Programs Steve Page, EPA Office of Air Quality Planning and Standards Anna Wood, EPA Air Quality Policy Division Juan Santiago, EPA Office of Air Quality Planning and Standards 8 i SAB Review of EPA’s Accounting Framework for Biogenic CO2 Emissions from Stationary Sources (September 2011), September 28, 2012; pg. 27. ii Thomas Walker et al., Biomass Sustainability and Carbon Policy Study, Manomet Center for Conservation Sciences, June 2010; Joshua Clark et al., Impacts of Thinning on Carbon Stores in the PNW: A Plot Level Analysis, Oregon State University, May, 2011; Stephen R. Mitchell et al., Carbon Debt and Carbon Sequestration Parity in Forest Bioenergy Production, Duke University and Oregon State University, May 2012; Hudiburg, T., B.E. Law, C. Wirth, S. Luyssaert. 2011. Regional CO2 implications of forest bioenergy production. Nature Climate Change 1:419-423. DOI: 10.1038/NCLIMATE1264; Hudiburg, T.W., S. Luyssaert, P.E. Thornton, B.E. Law. 2013. Interactive effects of environmental change and management strategies on regional forest carbon emissions. Environmental Science & Technology 47(22):13132-40. Doi: 10.1021/es402903u. iii See endnote ii above and: Biomass Supply and Carbon Accounting for Southeastern Forests, February 2012 at biomasscenter.org/images/stories/SE_Carbon_Study_FINAL_2-6-12.pdf ;Buchholz, Thomas et. al.; A global meta-analysis of forest bioenergy greenhouse gas emissions accounting studies (1991-2013), presented at The Transatlantic Trade in Wood for Energy: A Dialogue on Sustainability Standards and Greenhouse Gas Emissions, Savannah, Georgia; October 23-24. iv SAB Review of EPA’s Accounting Framework for Biogenic CO2 Emissions from Stationary Sources (September 2011), September 28, 2012; pg. 5.
Posted on: Tue, 01 Jul 2014 02:56:15 +0000
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