Carbon Neutrality of Biomass
Paper and wood products mills use biomass residuals from their manufacturing operations to generate bioenergy. The energy is used to make products and it provides significant greenhouse gas reduction benefits to the environment. AF&PA urges policymakers to clearly recognize our industry’s use of biomass for energy as carbon neutral.
Prior to 2010, the U.S. clearly recognized forest-based biomass energy as carbon neutral. In EPA’s Greenhouse Gas (GHG) Tailoring Rule, for the first time, no such designation was made, subjecting biomass energy used in stationary sources to Clean Air Act permit program requirements. In 2011, EPA issued a rule deferring regulation of biogenic CO2 emissions while it studied the issue and pledged to complete an accounting framework for biogenic emissions from stationary sources by July of 2014.
Numerous EPA documents and policy memo’s have found positive benefits from forest biomass use, including EPA’s original draft accounting framework (September 2011) and revised draft framework (November 2014). Both documents recognize the GHG reduction benefits of bioenergy from forest product mill residuals and byproducts, including black liquor. In addition, EPA indicated that use of sustainably derived timber also may be carbon neutral. EPA referred the matter to its Science Advisory Board, which still has not completed its work. After years of study, there is no timetable for resolution. Until EPA completes the framework and/or rulemaking, these carbon neutral emissions are subject to regulation under the Clean Air Act.
The carbon neutrality of biomass harvested from sustainably-managed forests has been recognized repeatedly by an abundance of studies, agencies, institutions, legislation and rules around the world, including the guidance of the Intergovernmental Panel on Climate Change and the reporting protocols of the United Nations Framework Convention on Climate Change.
Congress has considered and should adopt legislation to provide our industry the legal certainty it needs regarding the carbon neutrality for all manufacturing residuals and sustainably-derived biomass.
Industry’s Responsible and Efficient Biomass Use:
The forest products industry is the largest producer and user of bioenergy of any industrial sector and has long-standing operations in the U.S. The creation and use of biomass energy in forest products mills is integral and incidental to the manufacture of products such as pulp, paper, packaging, tissue and wood products. Pulp mills, integrated pulp and paper mills and wood products mills convert biomass residuals to energy while manufacturing biobased products that are useful to society. This sustainable use of forest products manufacturing residuals for energy provides enormous greenhouse gas benefits by avoiding the emission of about 181 million metric tons of CO2 equivalent. This is equivalent to the emissions of about 35 million cars. The forest products industry has created a highly efficient, market-based system of managed forest use with significant carbon benefits including:
- Providing biomass power by utilizing forest and mill residuals;
- Efficiently using biomass residuals through combined heat and power systems to assure forest biomass resources minimize total forest system GHG emissions;
- Reducing the industry’s and our nation’s reliance on fossil fuels and reducing GHG emissions while simultaneously meeting society’s needs for forest products;
- Reducing potential GHG emissions that otherwise would result from residual disposal (e.g., methane from decomposition);
- Balancing forest supply and demand through market-based systems for biomass due to forest planting and re-growth, as evidenced by net increases in forest carbon stocks over most of the last 50 years; and
- Robustly recycling paper to reuse valuable biomass resources.
These carbon benefits can be perpetuated if forests continue to remain abundant and well managed, with forest use and growth balancing supply and demand.
Science of the Natural Carbon Cycle:
As forests grow, CO2 is removed from the atmosphere via photosynthesis. This CO2 is converted into organic carbon and stored in woody biomass. Trees release the stored carbon when they die, decay or are combusted. As the biomass releases carbon as CO2, the carbon cycle is completed. The carbon in biomass will return to the atmosphere regardless of whether it is burned for energy, allowed to biodegrade or lost in a forest fire. The net impact of these processes is that CO2 flows in and out of forests and through the forest products industry by both biomass combustion and sequestration in products. Overall, the flow of forest CO2 is carbon positive when forests are sustainably managed, and the forest system remains a net sink of CO2 from the atmosphere. Thus, the carbon neutrality of sustainably-managed forest biomass is a scientifically-supported fact.
- Biogenic CO2 Emissions Should Be Deregulated. Scientific studies and EPA’s work shows that the use of forest products manufacturing residuals for energy not only has a deminimis impact on atmospheric concentrations of GHGs, but also can reduce net atmospheric GHG concentrations. Accordingly, Congress or EPA should ensure that biogenic CO2 is not subject to the regulation, such as EPA’s Clean Air Act permitting requirements for GHGs.
- Energy from biomass residuals, including from manufacturing mills and harvests, as well as biowastes, should be explicitly acknowledged for avoiding and reducing GHG emissions and promoting the efficient use of domestic natural resources. These wood residuals would have been disposed of by landfilling or incineration and thereby released GHSs to the atmosphere anyway if they had not been used as fuel.
- Biomass used to generate energy should be treated as carbon neutral where forest carbon stocks are stable or rising on a broad regional scale using U.S. Forest Service Forest Inventory Analysis data.
- Public policies should not construct artificial mandates or incentives that disrupt the nation’s existing efficient forest biomass markets.
- Policies that increase demand for forest-based renewable energy must be coupled with policies to increase biomass supply.
Public policies should recognize that sustainably-managed forests and forest products sequester and store carbon and reduce GHGs.