By Donna Harman
President & CEO
Paper Age, July/August Edition
I once heard the Pulp and Paperworkers’ Resource Council say
(about our industry) that “we were green before green was cool.” And
when it comes to the carbon neutrality of biomass, there is no
Latest in its series of greenhouse gas (GHG) regulations, the U.S. Environmental Protection Agency (EPA) released its proposed Existing Source Performance Standards (ESPS) for power plants, which call for a 30 percent emissions reduction by 2030. Our greatest concern with this rule is that it will increase our facilities’ purchased electricity costs; however, it also sets a bad precedent for how biogenic emissions will be treated going forward. Although the standards mention the positive role that biomass-derived fuels can play in GHG reduction strategies, they essentially treat biogenic and fossil fuel CO2 the same. As we know, recovering biomass residuals for energy production is not the same as burning fossil fuels or purchasing fossil fuel-based electricity from the grid. Now is the time for EPA to fully recognize the benefits of paper mill biomass fuels in their regulations and policy.
EPA has been working for three years on an Accounting Framework for Biogenic CO2 Emissions from Stationary Sources. AF&PA expects a revised draft to be released soon. Once finalized, the framework will clarify what biomass qualifies as “carbon neutral” (and therefore excluded from regulation of GHG emissions).
The carbon neutrality of biomass-based energy was not always this uncertain. Only after 2009 was it questioned when the Environmental Defense Fund and others challenged the concept of carbon neutrality in a Science journal article. The following year, EPA excluded smaller CO2 emitters like churches and small businesses from regulation through its GHG Tailoring Rule. But in doing so, EPA failed for the first time to distinguish biogenic emissions from fossil fuel emissions and did not exclude biogenic CO2 from Prevention of Significant Deterioration (PSD) / Title V permitting thresholds. After industry expressed concern over the potential far-reaching implications of this decision, EPA imposed a three-year deferral of biogenic CO2 regulations (the “Deferral Rule”) while it completed a scientific review of the issue. Environmental groups challenged the legality of the agency’s deferral, and on July 12, 2013, the D.C. Circuit Court vacated the rule, stating EPA had not adequately justified the basis for the deferral.
In the midst of the Deferral Rule activity and after considering public comments on the carbon neutrality issue, EPA issued a draft accounting framework; and even more recently on June 23, the Supreme Court ruled that EPA partially overstepped its authority in how it regulates GHG emissions from stationary sources in the Tailoring Rule. This brings us to now, where we are still in limbo, waiting for the revised framework to know how biomass emissions will be counted going forward for EPA’s current and proposed regulations.
In addition to pushing for a favorable carbon accounting framework, AF&PA continues to advocate that the Clean Air Act is the wrong tool for regulating GHG emissions. It imposes inflexible requirements that result in unnecessary and costly expenditures for manufacturing facilities. The ESPS is just one example in a string of regulations that contribute to the mounting costs of the administration’s GHG policy. For paper manufacturers that means higher purchased electricity costs and no assurance that our own internally-produced biomass energy will be treated as carbon neutral for PSD permits.
Our industry’s commitments to renewable biomass energy and energy efficiency, which include our use of highly-efficient combined heat and power technology, have already led to a dramatic decrease in fossil fuel use and GHG emissions. Since 1990, AF&PA members have decreased fossil fuel use in their pulp and paper mills by 34 percent, helping to reduce our industry’s greenhouse GHG emissions by 14.5 percent since 2005 and nearly reaching the goal of a 15-percent reduction set forth in our Better Practices, Better Planet 2020 sustainability initiative.
The fact is that biomass-based energy – particularly our use of manufacturing residuals – is an important part of a sustainable carbon cycle that has long been accepted not only within our industry, but also by the scientific community at large. It’s AF&PA’s mission to ensure that EPA recognizes our industry’s contributions to the larger “green” picture, and we believe that we’re close to doing just that. It’s time for EPA to recognize that biomass energy is part of the solution to reduce GHG emissions.