May 17, 2010

The Honorable Nancy Pelosi

Speaker

U.S. House of Representatives

235 Cannon House Office Building

Washington, DC 20515-0508

Fax: (202)225-4188

The Honorable Harry Reid

Majority Leader

United States Senate

522 Hart Senate Office Building

Washington, DC 20510-2803

Fax: (202) 224-7327

Dear Speaker Pelosi and Majority Leader Senator Reid, 

We write to bring to your attention the importance of accurately accounting for carbon dioxide 

emissions from bioenergy in any law or regulation designed to reduce greenhouse gas emissions from 

energy use. Proper accounting can enable bioenergy to contribute to greenhouse gas reductions; 

improper accounting can lead to increases in greenhouse gas emissions both domestically and 

internationally.

Replacement of fossil fuels with bioenergy does not directly stop carbon dioxide emissions from 

tailpipes or smokestacks. Although fossil fuel emissions are reduced or eliminated, the combustion of 

biomass replaces fossil emissions with its own emissions (which may even be higher per unit of energy 

because of the lower energy to carbon ratio of biomass). Bioenergy can reduce atmospheric carbon 

dioxide if land and plants are managed to take up additional carbon dioxide beyond what they would 

absorb without bioenergy. Alternatively, bioenergy can use some vegetative residues that would 

otherwise decompose and release carbon to the atmosphere rapidly. Whether land and plants 

sequester additional carbon to offset emissions from burning the biomass depends on changes both in 

the rates of plant growth and in the carbon storage in plants and soils. For example, planting fastgrowing energy crops on otherwise unproductive land leads to additional carbon absorption by plants 

that offsets emissions from their use for energy without displacing carbon storage in plants and soils. On 

the other hand, clearing or cutting forests for energy, either to burn trees directly in power plants or to 

replace forests with bioenergy crops, has the net effect of releasing otherwise sequestered carbon into 

the atmosphere, just like the extraction and burning of fossil fuels. That creates a carbon debt, may 

reduce ongoing carbon uptake by the forest, and as a result may increase net greenhouse gas emissions 

for an extended time period and thereby undercut greenhouse gas reductions needed over the next 

several decades1

Many international treaties and domestic laws and bills account for bioenergy incorrectly by treating all 

bioenergy as causing a 100% reduction in emissions regardless of the source of the biomass. They 

perpetuate this error by exempting carbon dioxide from bioenergy from national emissions limits or 

from domestic requirements to hold allowances for energy emissions. Most renewable energy standards 

for electric utilities have the same effect because bioenergy is viewed as a renewable energy even when 

the biomass does not eliminate or even reduce greenhouse gas emissions. This general approach 

. 

 1 J. Fargione, J. Hill, Tilman D., Polasky S., Hawthorne P (2008), Land Clearing and the Biofuel Carbon Debt, Science 319:1235-1238
appears to be based on a misunderstanding of IPCC guidance2

U.S. laws will also influence world treatment of bioenergy. A number of studies in distinguished journals 

have estimated that globally improper accounting of bioenergy could lead to large-scale clearing of the 

world’s forests

. Under some scenarios, this approach 

could eliminate most of the expected greenhouse gas reductions during the next several decades.

3

The lesson is that any legal measure to reduce greenhouse gas emissions must include a system to 

differentiate emissions from bioenergy based on the source of the biomass. The National Academy of 

Sciences has estimated significant potential energy production from the right sources of biomass

. 

4

Sincerely, 

. 

Proper accounting will provide incentives for these sources of bioenergy.

 2 T.D. Searchinger, S.P. Hamburg,J.Melillo, W. Chameides, P.Havlik,D.M. Kammen, G.E. Likens, R. N. Lubowski, M. Obersteiner, M. 

Oppenheimer,G. P. Robertson, W.H. Schlesinger, G.D. Tilman (2009), Fixing a Critical Climate Accounting Error, Science 326:527-528

3 E.g., J.M. Mellillo, J.M. Reilly, D.W. Kicklighter, A.C. Gurgel, T.W. Cronin, S. Patsev, B.S. Felzer, X. Wang, C.A. Schlosser (2009), Indirect 

Emissions from Biofuels: How Important?, Science 326:1397-1399; Marshall Wise, Katherine Calvin, Allison Thomson, Leon Clarke, Benjamin 

Bond-Lamberty, Ronald Sands, Steven J. Smith, Anthony Janetos, James Edmonds (2009), Implications of Limiting CO2 Concentrations for Land 

Use and Energy, Science 324:1183-1186

4 National Research Council (2009), Liquid Transportation Fuels from Coal and Biomass: Technological Status, Costs, and Environmental Impacts 

(National Academy of Sciences, Washington, D.C.)
William H. Schlesinger 

(Member, National Academy of Sciences)

President 

(Past President, Ecological Society of America)

Cary Institute of Ecosystem Studies

Millbrook, New York

Michael Allen

Director of the Center for Conservation Biology

Chair of the Department of Plant Pathology and 

Microbiology 

University of California, Riverside

Riverside, California

Viney P. Aneja

Professor Air Quality

Professor Environmental Technology

Department of Marine, Earth, and Atmospheric 

Sciences 

North Carolina State University 

Raleigh, North Carolina

Gary W. Barrett

Eugene P. Odum Chair of Ecology

Odum School of Ecology

University of Georgia

Athens, Georgia

Mark Battle

Associate Professor

Physics & Astronomy

Bowdoin College

Brunswick, Maine

Sharon Billings

Associate Professor

Department of Ecology and Evolutionary 

Biology

Kansas Biological Survey

Lawrence, Kansas

Mark A. Bradford

Assistant Professor of Terrestrial Ecosystem 

Ecology

Yale School of Forestry and Environmental 

Studies

Yale University 

Donald Kennedy

(Member, National Academy of Sciences)

Bing Professor Environmental Science and 

Policy

President, Emeritus

Stanford University

Stanford, California

New Haven, Connecticut

Phil Camill

Rusack Associate Professor of Environmental 

Studies 

Earth and Oceanographic Science Director, 

Environmental Studies 

Bowdoin College 

Brunswick, Maine

Elliott Campbell

Assistant Professor

School of Engineering & Sierra Nevada Research 

Institute

University of California, Merced

Merced, California

Joseph Craine

Assistant Professor

Division of Biology

Kansas State University

Manhattan, Kansas

Stephen R. Carpenter 

(Member, U.S. National Academy of Sciences)

Director and Professor

(Past President, Ecological Society of America)

Center for Limnology

University of Wisconsin

Madison, Wisconsin

Sallie (Penny) Chisholm

(Member, National Academy of Sciences)

Martin Professor of Environmental Studies

Massachusetts Institute of Technology

Cambridge, Massachusetts
Eric Chivian

(Shared 1985, Nobel Peace Prize)

Director

Center for Health and the Global Environment

Harvard Medical School

Cambridge, Massachusetts

Norm Christensen

(Past President, Ecological Society America)

Professor of Ecology

Nicholas School of the Environment

Duke University

Durham, North Carolina

James S. Clark

Hugo Blomquist Professor

Nicholas School of the Environment/Dept 

Biology

Duke University

Durham, North Carolina

Jon Cole

Distinguished Senior Scientist and G.E. 

Hutchinson Chair

Cary Institute of Ecosystem Studies

Millbrook, New York. 

Gretchen C. Daily

(Member, National Academy of Sciences)

Stanford University

Stanford, California

Frank P. Day

Professor of Biological Sciences and Eminent 

Scholar

Old Dominion University

Norfolk, Virginia

Seth DeBolt

Assistant Professor

Horticulture Department

University of Kentucky

Lexington, Kentucky

Evan H. DeLucia

G. William Arends Professor of Integrative 

Biology & Director, 

School of Integrative Biology 

University of Illinois

Urbana, Illinois

Samir Doshi

Gund Institute for Ecological Economics

University of Vermont

Burlington, Vermont

Dr. Charles T. Driscoll

(Member, National Academy of Engineering)

University Professor

Department of Civil and Environmental 

Engineering

Syracuse University

Syracuse, New York

Paul R. Ehrlich

(Member, National Academy of Sciences)

Bing Professor of Biology and 

President, Center for Conservation Biology 

Stanford University, 

Stanford, California

James Ehleringer

Distinguished Professor of Biology

Director, Global Change and Ecosystem Center

University of Utah

Salt Lake City, Utah

Erle C. Ellis

Associate Professor

Department of Geography & Environmental 

Systems

University of Maryland, Baltimore County

Baltimore, Maryland

Paul R. Epstein, M.D.

Associate Director

Center for Health and the Global Environment

Harvard Medical School

Boston, Massachusetts
Paul Falkowski

(Member of the National Academy of Sciences)

Board of Governors' Professor 

Marine, Earth and Planetary Sciences

Rutgers University

New Brunswick, New Jersey

Adrien Finzi

Associate Professor

Department of Biology

Boston University 

Boston, Massachusetts

Andrew J. Friedland

The Richard and Jane Pearl Professor in 

Environmental Studies 

Chair, Environmental Studies Program 

Dartmouth College

Hanover, New Hampshire

James N. Galloway

Department of Environmental Sciences

University of Virginia

Charlottesville, Virginia

Frank S. Gilliam

Department of Biological Sciences

Marshall University

Huntington, West Virginia

Christine L. Goodale

Assistant Professor

Department of Ecology & Evolutionary Biology

Cornell University

Ithaca, New York

Nancy B. Grimm

(Past President, Ecological Society America)

Professor,

Department of Biology

Arizona State University

Phoenix, Arizona

Peter M. Groffman

Senior Scientist

Cary Institute of Ecosystem Studies

Millbrook, New York

Nick M. Haddad

Associate Professor

Department of Biology

North Carolina State University

Raleigh, North Carolina

Charles A.S. Hall

College of Environmental Science and Forestry 

State University of New York

Syracuse New York 

John Harte

Professor of Ecosystem Sciences

Energy and Resources Group

University of California

Berkeley, California

Harold Hemond

W. E. Leonhard Professor of Civil and 

Environmental Engineering 

Massachusetts Institute of Technology 

Cambridge, Massachusetts

Sarah Hobbie

Associate Professor

Department of Ecology, Evolution, and Behavior

University of Minnesota

Minneapolis, Minnesota

Kirsten Hofmockel

Department of Ecology, Evolution, & 

Organismal Biology

Iowa State University

Ames, Iowa

R.A. Houghton

Deputy Director and Senior Scientist

Woods Hole Research Center

Falmouth, Massachusetts

Benjamin Houlton

Assistant Professor, Terrestrial Biogeochemistry 

Department of Land, Air and Water Resources 

University of California at Davis

Davis, California
Robert W. Howarth

David R. Atkinson Professor of Ecology and 

Environmental Biology

Cornell University

Ithaca, New York

A. Hope Jahren

Department of Geology & Geophysics 

University of Hawaii 

Honolulu, Hawaii

Dan Janzen

DiMaura Professor of Conservation Biology 

University of Pennsylvania 

Philadelphia, Pennsylvania

Daniel Kammen

Class of 1935 Distinguished Professor of Energy

Professor in the Energy and Resources Group 

and in the Goldman School of Public Policy

Director, Renewable and Appropriate Energy 

Laboratory

University of California, Berkeley

Berkeley, California

William S. Keeton

Associate Professor

Center for Natural Resources 

Rubenstein School of Environment and Natural 

Resources 

University of Vermont 

Burlington, Vermont

Thomas H. Kunz

Professor and Director

Center for Ecology and Conservation Biology

Department of Biology

Boston University

Boston, Massachusetts

Beverly Law

Professor, Global Change Forest Science

Department of Forest Ecosystems & Society

College of Forestry

Oregon State University

Corvallis, Oregon

John Lichter

Associate Professor

Department of Biology

Bowdoin College

Brunswick, Maine

Gene E. Likens

(Member, National Academy of Sciences)

Distinguished Senior Scientist

(Past President, Ecological Society America)

Founding President, Emeritus 

(Recipient, 2005, National Medal of Science)

Cary Institute of Ecosystem Studies

Millbrook, New York

Thomas Lovejoy

Heinz Center Biodiversity Chair

Heinz Center for Environment

Washington, D.C.

Daniel Markewitz

Associate Professor 

Warnell School of Forestry and 

Natural Resources

University of Georgia

Athens, Georgia

Roz Naylor

Professor, Environmental Earth Science;

William Wrigley Senior Fellow, and 

Director, Program on Food Security and the 

Environment

Stanford University

Stanford, California 

Jason Neff

Associate Professor

Geological Sciences and Environmental Studies

University of Colorado at Boulder

Boulder, Colorado

Michael O’Hare

Professor of Public Policy

Goldman School of Public Policy

University of California at Berkeley

Berkeley, California
Scott Ollinger

Associate Professor of Natural Resources

Complex Systems Research Center

Institute for the Study of Earth, Oceans and 

Space

University of New Hampshire

Durham, New Hampshire

Michael Oppenheimer

Albert G. Milbank Professor of Geosciences and 

International Affairs

Woodrow Wilson School

Princeton University

Princeton, New Jersey

Margaret A. Palmer

Professor and Director

Chesapeake Biological Lab

University of Maryland

College Park, Maryland

Todd Palmer

Department of Biology

University of Florida

Gainesville, Florida

Richard P. Phillips

Assistant Professor

Department of Biology

Indiana University

Bloomington, Indiana

Stuart Pimm

Doris Duke Professor of Conservation Ecology 

Nicholas School of the Environment

Duke University 

Durham, North Carolina

Jennifer S. Powers

Assistant Professor

Department of Ecology, Evolution & Behavior

University of Minnesota

Minneapolis, Minnesota

James W. Raich

Professor

Department of Ecology, Evolution & Organismal 

Biology 

Iowa State University

Ames, Iowa

Chantal D Reid

Assistant Professor of the Practice

Department of Biology and 

Nicholas School of the Environment

Duke University

Durham, North Carolina

William A. Reiners

Professor of Botany and

J.E. Warren Professor of Energy and 

Environment

University of Wyoming

Laramie, Wyoming

Heather Reynolds

Associate Professor

Department of Biology

Indiana University

Bloomington Indiana

G. Philip Robertson

University Distinguished Professor

W.K. Kellogg Biological Station and

Department of Crop and Soil Sciences

Michigan State University

Hickory Corners, Michigan

Steve Running

Regents Professor and Director, 

Numerical Terradynamic Simulation Group 

Department of Ecosystem Sciences 

University of Montana 

Missoula, Montana

Lee Schipper

Project Scientist

Global Metropolitan Studies

UC Berkeley

And Senior Research Engineer

Precourt Energy Efficiency Center

Stanford University
Stephen H. Schneider 

(Member, National Academy of Sciences)

Melvin and Joan Lane Professor for 

Interdisciplinary Environmental Studies,

Professor, Department of Biology and

Senior Fellow, Woods Institute for the 

Environment

Stanford University

Stanford, California

H.H. Shugart

W.W. Corcoran Professor

Department of Environmental Sciences

University of Virginia

Charlottesville, Virginia 

Kirk R. Smith 

(Member, National Academy of Sciences)

Professor of Global Environmental Health 

Director, Global Health and Environment 

Program 

School of Public Health 

University of California

Berkeley, California

Stanley D. Smith

Associate Vice President for Research 

Professor of Life Sciences 

University of Nevada 

Las Vegas, Nevada

Robert Socolow

Department of Mechanical and Aerospace 

Engineering

Director of the Carbon Mitigation Initiative 

Princeton University

Princeton, New Jersey

John Sperry

Professor

Biology Department

University of Utah

Salt Lake City, Utah

Dan Sperling

Professor and Director

Institute of Transportation Studies

University of California

Davis, California

Jennifer L. Tank 

Galla Associate Professor of Ecology

Department of Biological Sciences

University of Notre Dame

Notre Dame, Indiana

Pamela Templer

Assistant Professor

Boston University

Boston, Massachusetts

John Terborgh

(Member, National Academy of Sciences)

Nicholas School of the Environment

Duke University

Durham, North Carolina

Thomas P. Tomich

W.K. Kellogg Endowed Chair in Sustainable Food 

Systems

Director, UC Davis Agricultural Sustainability 

Institute

Director, UC Sustainable Agriculture Research 

and Education Program

Professor of Community Development, 

Environmental Science & Policy

University of California

Davis, California

Alan R. Townsend

Professor, Institute of Arctic and Alpine 

Research and

Department of Ecology and Evolutionary 

Biology

Director, Environmental Studies Program

University of Colorado 

Boulder, Colorado
Ross A. Virginia

Myers Family Professor of Environmental 

Science 

Director, Institute of Arctic Studies 

Dartmouth College

Hanover, New Hampshire

Diana H. Wall

(Past President, Ecological Society of America)

University Distinguished Professor

Director, School of Global Environmental 

Sustainability 

Colorado State University

Fort Collins, Colorado

Matthew Wallenstein

Research Scientist

Natural Resource Ecology Laboratory

Colorado State University

Fort Collins, Colorado

Thomas R. Wentworth

Alumni Distinguished Undergraduate Professor 

of Plant Biology 

North Carolina State University

Raleigh, North Carolina

Donald R. Zak

Burton V. Barnes Collegiate Professor of Ecology

University of Michigan

Ann Arbor, Michigan

Cc: Carol Browner, White House Office of Energy and Climate Change Policy

Lisa Jackson, Environmental Protection Agency

Steven Chu, Ph.D, Department of Energy

John Holdren, Ph.D, President’s Council of Advisors on Science and Technology