"With today's proposed framework, it appears that the EPA has chosen to avoid the difficult but important question of accounting for the net carbon pollution from forest-derived fuels for pulp and paper production. The forest products industry is the nation's largest user of bioenergy and the largest carbon polluter from this type of fuel, and an exemption for this feedstock is a missed opportunity for incentivizing efficiencies, protection of High Conservation Value Forests, and responsible, low-carbon forestry across the United States. The proposal to trace sourcing of forest-derived fuel for bioenergy back to the forest for some stationary sources but entirely exempt those that simultaneously produce a product, such as paper, is arbitrary and inconsistent. The science clearly shows that interrupting forest growth, manufacturing short-lived products and incinerating much of it for the large amount of energy required to power pulp and paper mills, results in a carbon debt within the timeframe necessary to keep atmospheric carbon below catastrophic levels.
The decision is contrary to the EPA's own tools for counting greenhouse gas emissions, which account for carbon emissions avoided by leaving a forest intact versus conversion to products and energy(1). While capturing and using the semi-organic waste from virgin fiber pulping is appropriate relative to burning additional fossil fuels, the science is clear that it is not carbon-neutral.
Unfortunately for the struggling US paper industry and its workers, its own continued assertion of blanket carbon-neutrality for this fuel source will ultimately weaken the industry's international competitiveness further in relation to the rising imports of paper products from tropical forests. In addition, the domestic recycled paper manufacturing industry will face a competitive disadvantage for producing sustainable paper products which are not manufactured using forest-derived fuels.
We look forward to completing an in-depth analysis of the documents released today and engaging the public and the scientific community to improve the final determination."
1. EPA. Forest Carbon Storage in WARM Model - October 27, 2010 - http://epa.gov/epawaste/conserve/tools/warm/pdfs/forest-carbon-storage-in-warm10-28-10.pdf
The Environmental Paper Network is an international collaborative project of more than 140 organizations who have endorsed the Global Paper Vision and are working for social and environmental transformation in the production and consumption of pulp and paper. Regional network leadership is provided by committees in North America (environmentalpaper.org), Europe (environmentalpaper.eu) and China (environmentalpaper.cn).