American 

Forest & Paper 

Association 

"' AMERICAN WOOD COUNCIL 

American Forest & Paper Association and American Wood Council 

Testimony Submitted for the Record 

U.S. Environmental Protection Agency 

EPA's Proposed "Carbon Pollution Emission Guidelines for Existing Stationary 

Sources: Electric Utility Generating Units" 

July 29, 2014 

Good morning. My name is Linda Tsang and I am the Director of Air Quality and 

Climate for the American Forest & Paper Association (AF&PA) and the American Wood 

Council (AWC). We appreciate this opportunity to provide our views on EPA's proposed 

carbon pollution emission guidelines for existing electric utility generating units. AF&PA 

primarily represents pulp and paper manufacturers and AWC primarily represents wood 

products manufacturers. 

EPA's "Clean Power Plan" impacts all users of electricity. The forest products industry 

is energy-intensive and spent over $5 billion on purchased electricity in '2011. Because 

we operate in a highly competitive global market, increases in our energy costs can 

significantly harm the competitiveness of the U.S. forest products industry. We have 

stated before that the Clean Air Act is the wrong tool to address greenhouse gas 

emissions, and we are concerned that EPA's proposal could have unintended 

consequences that negatively impact our economy. 

For the time being, the Plan treats biomass C02 emissions the same as fossil fuel 

emissions even though EPA acknowledges that using biomass for energy can have 

climate benefits compared to using fossil fuels and can help reduce greenhouse gases. 

Our industry's products and the manner in which we produce and use biomass energy 

are all part of the sustainable carbon cycle. C02 is stored as carbon in the trees and 

then released when the trees die, decay or are combusted. Wood residuals from forest 

product mills such as bark would have decayed and released C02 to the atmosphere 

anyway if they had not been used to produce energy and displace fossil fuels. The use 

of biomass for energy production is not the same as burning fossil fuels or purchasing 

fossil fuel-based electricity, and the time has come for EPA to fully recognize this in their 

regulations and policy. 

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In the Plan, EPA clearly signals they anticipate that states will likely consider using 

biomass to help meet the emission reduction requirements of the rule and says that the 

Accounting Framework for Biogenic C02 emissions, when finalized, will be a resource to 

help inform states in developing their compliance plans. Parties interested in biomassrelated issues are deprived of their rightful opportunity to fully comment on the Plan until 

EPA issues the revised Accounting Framework that will determine the central issue of 

biomass carbon neutrality. 

We believe that EPA's Accounting Framework should be simple and practical and be 

based on the best available data. The Framework should reflect data that shows that 

the use of manufacturing residuals for energy generates greenhouse gas reduction 

benefits. In addition, the Framework should avoid the use of an anticipated baseline 

based on modeling assumptions because it is inaccurate, unduly complicated, and 

costly to implement. In contrast, a reference baseline that uses historical and current 

data more accurately assesses if there are any atmospheric impacts from the use of 

biomass for energy. 

AF&PA and AWC urge EPA to complete its Accounting Framework, acknowledge these 

carbon neutrality principles, apply them consistently to its regulations, and provide clear 

guidance on how the Framework should be incorporated into state implementation 

plans. 

Given the importance and far reaching impact of EPA's regulation of greenhouse gases 

from the power sector, EPA must fully examine the Plan's impact on various 

manufacturing industries and commit to addressing biomass used for energy. 

Thank you for your time and consideration. 

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