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

in ternationally.

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

a bsorb 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 fast

growing 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 t ime period and thereby undercut greenhouse gas reductions needed over the next

several decades 1

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

bioenergy as causing a 100% reduction in emissions r egardless 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

- 1238appears to be based on a misunderstanding of IPCC guidance 2

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

have estimated that globall y improper accounting of bioenergy could lead to large

- scale clearing of the

world’s forests . Under som e 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 t he 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 s ources 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. Oberstein er, 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), Im plications 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 Sci ences, 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

N orth 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

Sha ron 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

Universi ty 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, Mass achusettsEric 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

Ni cholas 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

Distinguis hed 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, MassachusettsPaul 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

Chai r, 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 St ate 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, CaliforniaRobert W. Howarth

David R. Atkinson Professor of Ecology and

Environmental Biology

Cornell University

Itha ca, 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 Unive rsity

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 Colleg e

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 Geor gia

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, CaliforniaScott 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. P hillips

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 o f 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 Cor ners, 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 UniversityStephen H. Schneider

(Member, National Academy of Sciences)

Melvin and Joan Lane Professor for

Interdisciplinary Environmental Studies,

Professor, Department of Biolo gy 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, Califo rnia

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 Un iversity

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 E cology and Evolutionary

Biology

Director, Environmental Studies Program

University of Colorado

Boulder, ColoradoRoss 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. Za k

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