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    On December 19, 2007, the President signed into law the Energy Independence and Security Act of 2007 (EISA). This law (PL 110-140) includes an increase in the national Renewable Fuel Standard (RFS) mandating the production of 36 billion gallons of renewable fuels by 2022. Within the mandate, 16 billion gallons must be produced from cellulosic feedstocks, such as wood, grasses, and agricultural residues. An important component of the RFS is a series of greenhouse gas emissions screens, essential safeguards that ensure renewable fuels will meet minimum verifiable reductions in greenhouse gas emissions. For renewable fuels (from new facilities) to qualify under the RFS, they must achieve at least a 20 percent reduction in direct and indirect lifecycle emissions compared to equivalent petroleum fuels. Cellulosic fuels are subject to a 60 percent emissions screen. Because of these stringent safeguards and the large quantity of fuels required, it is paramount that we not exclude feedstocks without valid reasons. The definition of ‘renewable biomass’ included in the law, however, does rule out a number of feedstocks, including some woody biomass from private forests.

    The definition includes usage of “planted trees and tree residue from actively managed tree plantations on non-federal land cleared at any time prior to enactment…” and “slash and pre-commercial thinnings that are from non-federal forestlands...” This language limits the use of merchantable trees to those coming from tree plantations. Only logging residues and pre-commercial trees can be used from naturally-regenerated forestlands. There are a number of reasons why a broader inclusion of private forests in the definition of renewable biomass would be beneficial for the RFS, global climate, and our forest.

     

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