Close of SAB Meeting Brings No Further Ruling on Biomass

On April 1, the EPA’s Scientific Advisory Board concluded its quality review meeting to assess the draft report of the Framework for Assessing Biogenic CO2 Emissions from Stationary Sources. At the close of the meeting, despite years of discussion and debate on the issue, it seemed that the group of forestry experts remained at an impasse as to how to advance a comprehensive biogenic carbon accounting framework to the EPA. If the meeting had finalized the Framework, the draft report would have been sent to EPA Administrator Gina McCarthy for final approval. The Framework has implications for biomass’ use as a compliance strategy under the Clean Power Plan, as well as other environmental regulations.

 

Establishing an Emissions ‘Factor’ for Biomass

In 2011, EPA tasked the independent Scientific Advisory Board (SAB) with finalizing key concepts for emissions associated with the use of biomass feedstocks to produce electricity (including wastes from forestry, agriculture, organics, manure, landfills, and waste water treatment plants). The SAB's concept for the Framework is to establish a factor for carbon emissions associated with the entire lifecycle of biomass feedstocks, including the growth, harvest, and processing of the biomass. 

In the 2010 Tailoring Rule, EPA decided to treat biogenic and fossil CO2 source emissions at the power plant smoke stack the same. Therefore, for biomass use to comply with environmental regulations, a complex accounting framework must be established to verify that the use of a particular biomass feedstock will reduce net CO2 emissions. When finalized, the Framework will guide the use of biomass in all environmental regulations.  

In their final draft to EPA, the SAB advises that the Framework use an approach that considers all the changes in a landscape when biomass is harvested – rather than considering just emissions at the stack. If examined at a landscape scale over a longer time horizon, biomass can be considered a benefit to carbon emissions. This approach is advocated for by the biomass industry, as well as many foresters and scientists.

The SAB, meanwhile, has expressed frustration that the EPA will not provide a policy context for the Framework. Emissions accounting will vary depending on the time scale – whether it is a shorter time horizon, or a longer one. Foes argue that emissions from biomass need to be negative by 2030, the final implementation date of the Clean Power Plan. This shortened time scale would disqualify most biomass feedstocks from being considered as compliance options under the plan. The biomass industry and many forestry scientists argue that a timescale that considers all the changes at the landscape level –approximately 100 years – is more appropriate.

 

Carbon Benefits of Biomass are Well Established

According to a March 21 letter from the National Association of University Forest Resources Programs (NAUFRP) to the EPA SAB, “the carbon benefits of sustainable forest biomass energy are well established.” NAUFRP represents 80 U.S. universities that have forest resource programs, and the letter was signed by 100 university scientists and foresters. Recognizing the need to find a middle ground between a simple regulatory framework and the complexity of biogenic carbon accounting, the letter asks EPA to consider carbon emissions over the long term, to use consistent time frames, and to consider the economic factors, such as planting decisions, that ultimately influence forest biomass.

Biomass groups have long sought a carbon neutral designation for power sourced from woody fuels, so long as forest stocks are stable or increasing. They argue that not only does the science support this theory, but also the U.S. Forest Service, the Department of Energy, and international climate bodies, who all support biomass as carbon neutral.  

 

The Debate Continues … With No Clear End Result

On March 23, 44 independent scientists wrote to EPA expressing their concerns about the use of biomass as carbon neutral power generation. According to their letter, “expanding use of forest bioenergy in the U.S. and Europe . . . has been occurring on mistaken views that such materials are ‘carbon neutral’ or low carbon.” Many of the signatories expressed the same concerns in earlier letters.

A recent study, co-authored by SAB chair and professor of agricultural and consumer economics at the University of Illinois, Dr. Mahdu Khana, found that even when exporting wood pellets from the southeastern U.S. to Europe, the emissions are still 74 to 85 percent less carbon intensive than coal-fired power. On Friday, she commented to fellow SAB panelists that the task before the SAB was to consider the carbon implications of biomass, not larger questions of forest sustainabilty or forestry management.

The debate over the use of biomass for electricity in the United States has largely centered on the use of roundwood (small diameter trees that have low economic value) for pellets. In the southeast, producers are using roundwood as well as waste products to produce pellets, largely for European export markets. 

The debate has largely missed another potential source of biomass: wildfire thinnings. 2015 was one of the most destructive wildfire seasons on record, with over 10 million acres burning and consuming over 50 percent of the Forest Service budget. Federal forests have suffered from decades of fire suppression and a backlog of forestry management. According to the USDA, 43 percent, or as many as 68 million acres of federal lands are in need of thinning and/or controlled burning to reduce wildfire risk and restore forest health.

Biomass power (including CHP) has the potential to create markets for forest thinning which otherwise have no value, are costly to remove from forests, and may otherwise contribute to wildfires and resultant air pollutants. Many Western states would like to move forward with biomass in their Clean Power Plan to address these issues, but there are no clear answers on how EPA expects them to do so.  With the SAB on hold until further notice, it’s not clear when a feasible solution will develop.

 

EPA will convene a separate biomass stakeholder panel on April 7.

 

For more information see:

EPA: Chartered SAB to review biogenic framework

Export of wood pellets from US to EU more environmentally friendly than coal

NAUFP Letter to EPA