UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

WASHINGTON. D.C. 20460 

OFFICE OF 

AIR AND RAOIATIOI'\ 

MEMORANDUM 

Subject: 

From: 

To: 

Summary of takeholder Meetings 

Carissa Cyran 

Dockets EPA-IIQ-OAR-20 13-0602. EPA-HQ-OAR-20 13-0603. and EPA-HQOAR-20 13-0495 

This memorandum summarizes meetings with stakeholders during the week of January 12. 2015. 

On January 13, Associate Assistant Administrator for Climate and Senior Counsel lor Air and 

Radiation Joseph Goffman met with representatives from National Resource Defense Council. 

Sign-in sheet attached. 

On January 14, Associate Assistant Administrator lor Climate and Senior Counsel for Air and 

Radiation Joseph Goffman spoke with David Tenny of the National Alliance of Forest Owners. 

On January 16, Associate Assistant Administrator for Climate and Senior Counsel for Air and 

Radiation Joseph GotTman spoke with lormer Colorado Governor Bill Ritter of the Cehter for the 

New Energy Economy. 

Internet Address (URLl • hllp 1/www epa gov 

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Date: January 13, 2015 

Meeting: General Discussion 

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NRDC FACT SHEET SEPTEMBER 2014 

F$.1 3-04-A 

Burning Trees for Electricity Will Accelerate 

Climate Change and Destroy Southern Forests 

Power companies in the United States and Europe are expanding their use of trees-known as woody 

biomass-as a fuel source to replace fossil fuels. The wood is chipped or turned 1nto pellets and burned 

in power plants just the same as coal. To meet this increasing demand, a new, rapidly growing industry of 

manufacturing facilities has emerged across the southeastern United States to supply wood fuel to electric 

utilities on both sides of the Atlantic. In the Southeast, the massive fuel needs of these energy companies 

could double logging rates and significantly increase carbon emissions. contributing to climate change 

at a time when we need to actively cut our carbon pollut1on. As Important. local forest ecosystems and 

watersheds could be devastated. 

OUR FORESTS AREN'T FUEl 

Americans know how valuable our forests are, in the 

Southeast and across the country. In addition to providing 

one of the best tools to fight climate change, forests filter 

water, give us open spaces to hunt, fish, and camp, and 

provide habitat to a multitude of species. If big power plants 

turn increasingly to whole trees for their fuel, it will intensify 

pressure to overharvest our forests, threatening our climate, 

wildlife, land, and water. For the biomass industry to grow in 

a way that helps reduce pollution and protects our forests, 

large power companies and pellet manufacturers must 

commit to a wood-sourcing policy that excludes whole trees. 

Over the past year alone. wood pellet exports from southeastern 

ports increased 70 percent. making the southern United States 

the largest exporter of wood pellets in the world. This growth is 

expected to continue: numerous additional manufacturing and 

export facilities are planned. particularly in the South. 

While some forms of woody biomass can reduce carbon 

emissions, burning whole trees and some larger woody debris 

for energy actually increases carbon pollution for decades 

compared with fossil fuels such as coal or natural gas. 

Unfortunately, as pellet manufacturers continue to source 

whole trees to produce wood fuel, and power companies 

invest heavily in biomass energy without long-term sourcing 

policies against burning whole trees, large-scale use of whole 

trees for energy production will create a growing demand for 

limited forest resources. This will not only exacerbate existing 

pressures on southern forests but also increase climate 

pollution. 

BURNING TREES FOR ENERGY INCREASES 

CARBON POllUTION FOR DECADES 

Power companies and pellet manufacturers promote biomass 

energy as a way to reduce carbon emissions and mitigate 

climate change. They argue that the carbon emitted when 

burning trees for energy is equal to the amount of carbon 

those trees have absorbed from the atmosphere while 

growing and a new tree will absorb as it grows. Until recently, 

energy from biomass was considered an important part of 

a robust portfolio of renewable energy sources- alongside 

such technologies as solar, wind, and geothermal-to 

address climate change. However, advances in science and 

accounting for pollution from different types of woody 

biomass have clarified that burning whole trees to produce 

electricity actually increases carbon emissions compared 

with fossil fue ls for many decades. There are two key reasons. 

• Burning trees for electricity is highly inefficient. By 

substitu ting trees for coal, power plants avoid fossil-fuel 

carbon emissions. But trees are approximately half water 

by weight, which means they contain less potential energy 

DC For more information about NRDC's Our Forests Aren't Fuel Campaign. please contact: 

Debbie Hammel dhammel@nrdc.org, http://switchboard.nrdc.org/blogs/dhammel 

Sasha Lyutse slyutse@nrdc.org, http://switchboard.nrdc.org/blogs/slyutse 

Scot Ouaranda scot@dogwoodalliance.org 

www.nrdc.org/forestsnotfuel 
per unit of carbon emissions than coal and othe r fossil 

fuels do. In other words, to get the same amount of energy 

from trees as from fossil fuels, many more trees have to be 

burned, resulting in 40 percent more carbon emissions at 

the smokestack per unit of energy generated. An d even if 

trees are replanted immediately, it takes many decades for 

a tree to grow and absorb all the carbon released from the 

burning of just one tree. 

• If lett alone, trees will continue to grow and absorb carbon 

out of t he atmosphere. In the United States, we count on 

our forests to expand each year, offsetting approximately 

13 percent of the carbon emissions coming from our 

facto ries, homes, and cars- the equivalent of taking 

more than 180 million cars off the road. ' Cutting trees 

down to burn as fuel in power plants means this carbon 

sequestration is lost. 

Together, the initial increase in carbon pollution at the 

smokestack and the lost carbon sequestration mean it can 

take new trees anywhe re from 40 years to more than 100 

years before there are carbon benefits from this kind of 

bioene rgy production.2 At a time when the United States 

urgently needs to clean up its power plants, a major shift to 

burn ing whole trees for energy production would not only 

increase carbon pollution but also degrade our forests-one 

of the country's best natural air scrubbers. 

Southern p.ne plantations are a major source of biomass for 

wood pellet manufacturers. Unlike natural forests, which are 

home to a rich and diverse array of plants and animals. tree 

plantations provide little biodiversity. In the early 1950s there 

were approximately 2 million acres of planted pine in the South. 

That figure has skyrocketed to more than 40 million acres of pine 

plantations today. According to the United States Forest Service. 

if current trends continue. pine plantations will likely increase by 

60 percent-to 54 million acres by 2040-and make up more than 

one-quarter of all regional woodlands, an area the size of North 

Carolina and South Carolina combined. 

INVESTMENTS IN WHOLE-TREE BIOENERGY 

SHIFT FOCUS AWAY FROM LOW-CARBON 

ENERGY SOLUTIONS 

We need utility companies to invest in expanding e nergy 

efficiency and clean, renewable, and truly low-carbon e nergy 

sources, such as solar, wind, and geothermal power. Investing 

in wood-burning power plants distracts from these efforts, 

a nd erodes hard-won victories for forest conservation. 

FEASIBLE, COST-EFFECTIVE ALTERNATIVES 

ARE AVAILABLE 

Clean waste products-the unused by-products of 

sustainable forestry that otherwise would be burned or 

would rapidly decay-and some timber harvest residuesthe small-diameter portion of tree tops and branches le ft 

after logging-can be good sources of biomass. If it is done 

right, timber residue can be removed in limited amounts 

from a forest without compromising soil health or wildlife 

habitat. Other dedicated biomass sources, if sustainably 

managed and grown on land that does not compete with 

food production, can offer a low-carbon supply of energy as 

long as the released carbon is reabsorbed quickly by growing 

replacement crops for more biomass. Perennial grasses such 

as switchgrass and short-rotation woody crops are examples. 

Real biomass solutions must not be established at the 

expense of natural forests. 

The Natural Resources Defense Cou nc il and Dogwood 

Alliance believe that large utility companies must shift to real 

renewables and that they a nd their pellet and chip suppliers 

must establish adequate policies to protect our climate 

and forests by committing not to use whole trees before 

expanding their biomass operations. 

U.S. Environmental Protection Agency, 2011 Inventory of U.S. Greenhouse Gas Emissions and Sinks, 

http://www.epa.gov/climatechange/ghgemissions/usinventoryreport.html. 

2 Based on findings from the following studies: Manomet Center for Conservation Sciences. Biomass Sustainability 

and Carbon Policy Study, June 201 0; Oregon State University, Impacts of Thinning on Carbon Stores in the PNW: A 

Plot Level Analysis, May, 2011; The Biomass Energy Resource Center, Forest Guild, and Spatial Informatics Group, 

Biomass Supply and Carbon Accounting for Southeastern Forests. February 2012; Duke University and Oregon State 

University, Carbon Debt and Carbon Sequestration Parity in Forest Bioenergy Production. May 2012. 

@Printed on recycled paper ©September 2014 Natural Resources Defense Council www.nrdc.org/forestsnotfuel www.nrdc.org/policy