## American Forest & 

## Paper Association "' AMERICANWOOD COUNCIL

American Forest & PaperAssociation and American Wood Council Testimony Submitted forthe Record U.S. Environmental Protection Agency

EPA's Proposed "Carbon Pollution Emission Guidelines for Existing Stationary Sources: Electric Utility Generating Units" July29, 2014
Good morning. My name is Linda Tsang and I am the Director ofAir Quality and Climate forthe American Forest & PaperAssociation (AF&PA) and the American Wood Council (AWC). We appreciate this opportunityto provide ourviews on EPA's proposed carbon pollution emission guidelinesfor 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 ofelectricity. 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 ourenergy costs can significantly harm the competitiveness ofthe U.S. forest products industry

. We have stated before thatthe Clean AirAct 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.

Forthe 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 ofthe sustainable carbon cycle. C02 is stored as carbon in the trees and then released when the trees die, decay orare combusted. Wood residuals from forest product mills such as barkwould have decayed and released C02 to the atmosphere anyway ifthey had not been used to produce energy and displace fossil fuels. The use of biomassforenergy production is notthe same as burning fossil fuels or purchasing fossil fuel-based electricity, and the time has come for EPAto fully recognize this in their regulations and policy.

1In the Plan, EPA clearly signals they anticipate that states will likelyconsider using biomass to help meetthe emission reduction requirements ofthe rule and says thatthe Accounting Frameworkfor 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 oftheir rightful opportunityto fully comment on the Plan until EPA issues the revised Accounting Framework thatwill 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 ofmanufacturing residuals for energy generates greenhouse gas reduction benefits. In addition, the Framework should avoid the use ofan anticipated baseline based on modeling assumptions because it is inaccurate, undulycomplicated, and costlyto implement. In contrast, a reference baseline that uses historical and current data more accurately assesses ifthere are any atmospheric impactsfrom the use of biomass for energy.

AF&PAand AWC urge EPAto complete its Accounting Framework, acknowledge these carbon neutrality principles, applythem consistently to its regulations, and provide clear guidance on howthe Framework should be incorporated into state implementation plans.

Given the importance and far reaching impact of EPA's regulation ofgreenhouse gases from the power sector, EPA mustfully examine the Plan's impact on various manufacturing industries and committo addressing biomass used for energy. Thankyou foryourtime and consideration.



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