Yesterday, Forisk Consulting released an analysis of EPA’s treatment of woody biomass under the Tailoring Rule. Sadly, the study, which was sponsored by the National Alliance of Forest Owners (NAFO), argues that EPA should stop doing its job and protecting the air we all breathe. To riff on the old saying, it’s not what the study’s author don’t know that gets them in trouble, it’s what they do know that just ain’t so. The study clings to bad science trying to masquerade as common sense and false choices between good jobs, clean energy, and a safe environment for our children. But a closer look at the analysis quickly reveals serious flaws in NAFO’s assumption that biomass coming out of the ground is magically carbon neutral and exaggerated claims about the impact of the Tailoring Rule on new woody biomass projects.
On a teleconference presenting the results of the study, NAFO spokesperson Dan Whiting repeatedly accused EPA of “not following the science” by ignoring the “natural carbon cycle.” According to NAFO, the carbon in currently managed forests is part of a regular cycle, sequestered as trees grow, released as those trees are turned into paper and lumber, and then re-sequestered when new trees are planted. Burning forests for electricity is just a new use for an old cycle, argues NAFO.
It sounds alluringly simple, right? But it just ain’t so. EPA is just more honest about the science than the industry. They’re not ignoring the carbon cycle; they’re just recognizing that the industry can easily mess up that cycle. EPA has said that they are going to count carbon going into the air from biomass just as they count carbon from fossil fuels. After all, it has the same impact on the climate once it’s up there.
EPA acknowledges that sometimes about the same amount of carbon as is released when biomass is burned for energy is reabsorbed when that biomass regrows, but sometimes more or less carbon is reabsorbed. Sometimes that reabsorption happens quickly, but sometimes it takes decades. (As anyone who has ever planted a tree knows, they can take a while to grow.) In other words, figuring out how to credit the reabsorption is complicated and that’s why EPA asked for comments and is carefully developing carbon accounting regulations. That’s EPA’s job.
NAFO’s cycle argument really falls apart when you look at the amount of forest they want to cut down. The cycle argument works best for currently managed forests producing wood and wood products for a whole variety of existing purposes. But new woody biomass-based energy projects by definition mean an expansion in the demand for woody biomass. Indeed, according to a summary of the impact study, 130 new woody biomass projects would be put “at risk” for cancellation or delay as a result of the Tailoring Rule. NAFO says these power plants would need 53.4 million tons of wood biomass per year from marketplace—or roughly 10% of today’s annual market.
Where will that biomass come from? Either it will have to be diverted from its current purposes, indirectly increasing pressure on forests elsewhere to satisfy prior demand, or it will mean cutting down new forests—forests whose carbon is only cycling in the atmosphere very slowly, over centuries—creating a massive “carbon debt” by releasing large pulses of carbon that it will take years to “pay down”. In either case, the myth that this woody biomass is somehow magically carbon neutral is just that—a myth. As we discussed (and illustrated) here, when trees are burned to produce electricity, the carbon in those trees is released into the atmosphere as carbon dioxide. This is carbon dioxide that was not in the atmosphere before being turned into energy and has exactly the same global warming effect as carbon dioxide from coal or any other fossil fuel once it enters the atmosphere. And it is carbon dioxide that must be counted when assessing the global warming impact of biomass-based energy projects.
In addition, while NAFO’s “fact sheet” claims that the Tailoring Rule has already delayed, put on hold or idled 23 developing woody biomass projects, Forisk’s actual report simply lumps the Tailoring Rule in with numerous factors that are the actual reasons why these biomass projects were undoubtedly delayed:
“Reasons cited by project developers for delayed plans or closures include low electricity prices/market conditions, uncertainty surrounding federal policies, such as the Tailoring Rule (including extended permitting timelines and other administrative requirements), state-level RPS guidelines and difficulties securing financing.”
Based on the actual report, the headline for NAFO’s press release could have just as easily been titled “Difficulties Securing Financing Jeopardize Renewable Energy Investment, Jobs, Production Goals.”
Which brings me to the last thing that just ain’t so in the NAFO study: making sure that America has 21st century biopower plants that help protect our forests instead of destroying them creates jobs. NAFO wants to be able to chop down trees without anyone looking over its shoulder, but building and installing pollution controls isn’t just good for our lungs and our landscapes—it means jobs. Building plants today that can survive in a carbon constrained world is what China is doing. It’s a good investment and we should be doing it too. And while there are many reasons why a woody biomass-based energy project may or may not move forward, ensuring that American energy facilities are fitted with the best available technologies will not only mean cleaner air but thousands of domestic jobs and a more competitive industrial sector.