In January of 2011, Environmental Protection Agency (EPA) announced that biomass energy facilities and other biogenic stationary sources will not need to account for their net carbon dioxide (CO2) emissions under the Clean Air Act’s Tailoring Rule for a period of three years. The Agency says that it needs these three years to conduct a detailed examination of science associated with biogenic CO2 emissions from bioenergy sources. On March 21, 2011, EPA published a proposed rule that reflected this announcement.
Given that The Wilderness Society has an interest in the development of biomass for energy and its effects on our nation’s public and private forests, we provided comments to EPA on May 5, 2011 (see below). These comments are related to biogenic CO2 accounting for biomass burning facilities under the Tailoring Rule. We have serious concerns about the unsustainable use of biomass that could negatively affect forest carbon stocks and other fundamental forests values, such as wildlife habitat, air and water quality, and the restoration of natural fire regimes.
The Wilderness Society is concerned that certain biomass projects can actually worsen carbon pollution. While some biomass production is carbon neutral, not all practices are equal. It makes a big difference whether the source of fuel is live trees from a mature forest compared to wood waste from a paper plant. In response to Call for Information on July 15, 2010, EPA received a great amount of scientific evidence which concludes that burning or co-firing biomass from expanded harvest of live trees is not carbon neutral in any timeframe meaningful to addressing climate change. The Wilderness Society urges EPA to take an appropriate action by following the science and no longer treating biomass as exempt from having to account for such emissions.
Click the link below to read the document.