EPA's Treatment of Biogenic Carbon Dioxide (C02) Emissions from Stationary Sources that Use Forest
Biomass for Energy Production
Introduction
The use of biomass from managed forests1 can provide numerous environmental, energy and economic
benefits. Specifically, forest biomass use for energy can bolster domestic energy production, provide
jobs to rural communities, and promote environmental stewardship by improving soil and water quality,
reducing wildfire risk, and helping to ensure our forests continue to remove carbon from the
atmosphere.
EPA recognizes the importance of the nation's forest resources and related industries, and the role that
biomass can play in renewable energy strategies. These principles are core elements of provisions in the
Consolidated Appropriations Act, 2018.1 Those provisions explicitly direct EPA, the Department of Energy
and the Department of Agriculture to establish policies that "reflect the carbon-neutrality of forest
bioenergy and recognize biomass as a renewable energy source, provided the use of forest biomass for
energy production does not cause conversion of forests to non-forest use." Such policies would also be
consistent with Executive Order 13783,3 Promoting Energy Independence and Economic Growth, which
requires executive agencies to review requirements that may hinder domestic energy production.
Furthermore, in response to Executive Order 13777, Enforcing the Regulatory Reform Agenda,4 many
forest and forest products industry stakeholders provided comments about uncertainty related to the
treatment of forest biomass used for energy in EPA programs. These comments explained that
regulatory uncertainty concerning biogenic carbon dioxide (C02) emissions from the use of forest
biomass for energy has made planning future investments riskier for these industries and forest
communities, hindering growth of the U.S. bioeconomy.
To proactively address congressional directives and stakeholder concerns specific to the use of forest
biomass for energy, EPA's policy in forthcoming regulatory actions will be to treat biogenic C02
emissions resulting from the combustion of biomass from managed forests at stationary sources for
energy production as carbon neutral. EPA's ongoing work under the Renewable Fuels Standard (RFS)
and Title II will not be impacted by this policy and will continue to be governed by the existing regulatory
and statutory process and requirements already in place.5
Policy Summary
EPA's rationale and basis for applying this policy is as follows. In treating biogenic C02 emissions
associated with the use of forest biomass for energy at stationary sources as carbon neutral, the Agency
has balanced the Executive Orders and Congressional direction described above with the following
considerations:
1 'Managed forest' is a forest subject to the process of planning and implementing practices for stewardship and
use of the forest aimed at fulfilling relevant ecological, economic and social functions of the forest (IPCC). Also, in
this document, it specifically comprises lands that are currently managed or those that are afforested, to ensure
the use of biomass for energy does not result in the conversion of forested lands to non-forest use.
2 https://www.congress.gov/115/bills/hrl625/BILLS-115hrl625enr.pdf
3 www.whitehouse.gov/presidential-actions/presidential-executive-order-promoting-energy-independence-
economic-growth/
4 https://www.gpo.gov/fdsys/pkg/FR-2017-06-28/pdf/2017-13551.pdf
5 https://www.epa.gov/renewable-fuel-standard-program/regulations-and-volume-standards-renewable-fuel-
standards
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• U.S. forests have been historically and are currently a net sink of carbon; in 2015, the forest
sector offset approximately 11.2 percent of gross U.S. greenhouse gas emissions.
• Use of biomass for bioenergy can support the management of U.S. forests and can lead to
increased carbon sequestration from U.S. forests over time.
• Draft EPA analysis suggests that use of various biomass feedstocks for energy at stationary
sources can result in negligible net contribution to atmospheric concentrations of C02 depending
on factors related to feedstock characteristics, production and consumption, and alternative
uses.
• Use of biomass feedstocks from managed forests for energy at stationary sources can provide
multiple environmental benefits, such as pest management, improved water and soil quality,
and wildfire risk reduction.
• Use of these biomass feedstocks for energy at stationary sources can provide numerous
economic benefits to rural communities, including new jobs and income from forest biomass
industry and support of existing tourism and recreation industries in forested areas.
• EPA's technical work on a framework for assessing the net atmospheric contribution of biogenic
C02 emissions from biomass feedstocks used by stationary sources for energy production,
includes an ongoing peer review by EPA's Science Advisory Board (SAB). However, this process
has not to date resulted in a workable, applied approach.
• Many forest and forest products industry stakeholders view the lack of a clear EPA policy on the
treatment of biogenic C02 emissions resulting from the combustion of forest biomass for energy
at stationary sources as an impediment to the use of biomass from managed forests for
bioenergy purposes, thus frustrating the realization of its expected environmental and economic
benefits.
The Agency's approach is a pragmatic one, promoting the environmental and economic benefits of the
use of forest biomass for energy at stationary sources, while balancing uncertainty and administrative
simplicity when making programmatic decisions.
This statement of agency policy is not a scientific determination and does not revise or amend any
scientific determinations that EPA has previously made. Rather, this statement of policy is intended to:
1) provide clear recognition of the benefits of using forest biomass for energy production at stationary
sources; and 2) signal the Agency's intent to treat the biogenic C02 emissions associated with the use of
forest biomass for energy by stationary sources as carbon neutral in future regulatory actions and in
various programmatic contexts, in accordance with the Executive Orders and Congressional direction
described above.
This statement of agency policy does not represent a final agency action and does not directly address
the treatment of biogenic C02 emissions at any particular stationary source or in any specific regulatory
context or other EPA program such as voluntary programs. Any changes to the current treatment of
biogenic C02 emissions at a specific entity or in a specific regulatory program or other context will be
accomplished through the appropriate mechanisms, including, as necessary, a notice of any proposed
rulemaking, the basis for such changes, and an opportunity for public comment.
Technical Summary
Through photosynthesis, plants absorb C02 from the atmosphere and add it to their biomass as carbon,
a process referred to as sequestration. When plant biomass is harvested or cleared from the land and
burned for energy, used as an input to an industrial process, or biodegraded as part of waste treatment
processes, the carbon in biomass is released into the atmosphere as C02.
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EPA tracks all anthropogenic greenhouse gas (GHG) emissions and sequestration, including those
resulting from the use of bioenergy, via the Inventory of U.S. Greenhouse Gas Emissions and Sinks.
Consistent with Intergovernmental Panel on Climate Change (IPCC) methodologies, the Inventory
provides a holistic approach to estimating carbon sequestration and GHG emissions at the national level
across all sectors. Biogenic C02 emissions related to activities affecting terrestrial carbon stocks, such as
harvesting trees, are captured within the land-use, land-use change, and forestry sector of the
Inventory, even if a portion of those emissions, such as the C02 emissions from biomass combustion,
ultimately take place at facilities typically associated with a different inventory sector (e.g., the energy
sector).6 This national land sector inventory approach is well suited to track national trends, but it
cannot attribute changes in forest carbon stocks to particular activities, such as the use of forest
biomass for energy.
The scientific and technical considerations relevant to assessment of the GHG emissions and other land
use-related outcomes from biomass use for energy production can be complex, as there are several
interrelated biophysical, energy and market systems underpinning biomass production and use.
Beginning in 2010, in response to stakeholder comments,7 EPA sought to advance the technical
understanding for assessing the net biogenic C02 emissions associated with the use of biomass at
stationary sources. In 2011, as part of this process to advance our technical understanding, EPA
submitted for peer review with the EPA Science Advisory Board (SAB) a draft technical report8
presenting considerations for evaluating the biogenic C02 emissions associated with biomass use for
energy at stationary sources (2011 Draft Framework). The SAB peer review of the 2011 Draft
Framework9 found that it is not scientifically valid to assume that all biogenic feedstocks are carbon
neutral, but rather that the net biogenic carbon profile related to the use of biomass feedstocks
depends upon factors related to feedstock characteristics, production and consumption, and alternative
uses. The SAB also asserted that use of some biomass feedstocks may have minimal net biogenic C02
emissions and others may require more analysis.10 Furthermore, the SAB also acknowledged that in
addition to scientific elements, EPA may need to consider the tradeoffs and benefits of different
accounting approaches and other practical implementation issues to inform policy choices when
6 While included in the reported net carbon sequestration/CC>2 emissions in the land-use sector of the Inventory,
the biogenic C02 emissions from combustion of biomass for energy are also quantified for informational purposes
in the energy sector of the Inventory as a memo item, but are not included in that sector's total to avoid double-
counting.
7 FR Notice [EPA-HQ-OAR-2010-0560; FRL-9175-9], Call for Information: Information on Greenhouse Gas
Emissions Associated with Bioenergy and Other Biogenic Sources
.
8 Draft Accounting Framework for Biogenic CO2 Emissions from Stationary Sources (2011) <
https://19january2017snapshot.epa.gov/sites/production/files/2016-08/documents/biogenic-co2-accounting-
framework-report-sept-2011.pdf>.
9 EPA Science Advisory Board Review of the 2011 Draft Accounting Framework for CO2 Emissions for Biogenic
Sources Study (2012)
.
10 A number of forest biomass feedstocks, such as certain industrial byproducts, have been demonstrated to result
in little to negligible contribution to net atmospheric concentrations of CChwhen used for energy at stationary
sources.
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assessing biogenic C02 emissions from stationary sources.9 The SAB further acknowledged that
accounting for biogenic C02 emissions associated with stationary sources involves both scientific and
policy considerations, including the policy context in which the accounting is applied.11
In November 2014, EPA released a revised second draft of its technical report (2014 Revised
Framework)12, which incorporated input from the SAB's review of the 2011 Draft Framework and
stakeholder comments and presented a potential framework for assessing biogenic C02 emissions. Final
recommendations from the SAB peer review process of the 2014 Revised Framework remain uncertain
as there is disagreement among the SAB on specific technical elements.13
As a result, while a valuable exercise, the lengthy and intensive process of assessment and discussion,
including among the SAB, has not to date resulted in a workable, applied approach for consistently
assessing the net atmospheric contribution of biogenic C02 emissions at stationary sources. In addition,
broader considerations also motivate EPA to establish this policy, including the substantial
environmental and economic benefits associated with the use of forest biomass, the benefits of
providing clarity to stakeholders, and direction from Congress and relevant Executive Orders.
National Forest Carbon Stocks and the Role of Bioenergy
While it is not possible to discern from national forest carbon stock estimates the effects of a particular
stationary source's use of forest biomass for energy, general U.S. carbon stock trends in the land sector,
including changes in forest biomass consumption, are captured in the Inventory of U.S. Greenhouse Gas
Emissions and Sinks. U.S. forested lands currently remove more C02 from the atmosphere than they
emit (i.e., they are a net sink of carbon); in 2015 the forest sector offset approximately 11.2 percent of
gross U.S. GHG emissions.14 While there is some uncertainty within the scientific community about
whether U.S. forests will remain a net carbon sink over the coming years, recent research shows that
under current market and environmental conditions, continued forest land investment and
management can allow for continued and even increased U.S. forest carbon stocks in the future.
Specifically, landowners can anticipate future markets for woody materials and accordingly invest in
forested lands.15
Changes in demand for forest-derived biomass could influence how U.S. land owners manage forests
and the related forest carbon stocks. For example, in the short term, increased biomass demand may
11 In fact, the SAB acknowledged in its review of both the Draft and Revised Frameworks that it was difficult to
conduct a scientific review of the Framework in the absence of information about the applied policy context in
which it would be used.
12 Revised Framework for Assessing Biogenic C02 Emissions from Stationary Sources. (2014) <
https://19january2017snapshot.epa.gov/sites/production/files/2016-08/documents/framework-for-assessing-
biogenic-co2-emissions.pdf>.
13 Disagreement remains between EPA's Biogenic Carbon Emissions Panel and the EPA Chartered SAB, specifically
on the issue of the timeframe for assessment of biogenic CO2 emissions from the use of biomass at stationary
sources. The disagreement is focused on whether the timeframe should be a policy-specific horizon or based on
the time horizon in which all terrestrial impacts (positive and negative) associated with biomass use for energy are
included.
14 Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2015 <
https://www.epa.gov/ghgemissions/inventory-us-greenhouse-gas-emissions-and-sinks-1990-2015>.
15 Tian, Xiaohui, Brent Sohngen, Justin Baker, Sara Ohrel, and Allen A. Fawcett. 2018. Will U.S. Forests Continue to
Be a Carbon Sink? Land Economics February 2018. 94 (1): 97-113. ISSN 0023-7639.
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change forest product market dynamics and how the forest industry sources materials. Stakeholders
have raised concerns regarding near term land-use changes in response to increased biomass demand.
Over time, stronger markets for biomass from managed lands could potentially bring more added value
to forested lands and lead to increased forested lands and carbon sequestration.16 This market
development could help reduce the conversion of forest lands to non-forest uses. EPA recognizes the
importance of ensuring the management of forests protects and conserves biologically sensitive areas
and, in the ongoing implementation of this policy, will continue to closely monitor overall bioenergy
demand and landscape conditions for changes that might have negative impacts on public health or the
environment. EPA will continue to evaluate the applicability of this policy of treating biogenic C02 as
carbon neutral based on relevant information, including data from interagency partners on updated
trends in forest carbon stocks. This safeguard, among others, serves to ensure that EPA periodically
assesses the need to revisit this treatment in the future.
Environmental and Economic Benefits of Bioenergy
EPA recognizes it is also important to consider additional roles of biomass and the land sector in GHG
mitigation strategies and in the economy. Biomass from forest management activities can provide
significant energy, economic, and environmental benefits to the U.S. For example, thinning and fuel
treatments in western states can reduce the risk of forest fires, while simultaneously providing an
energy source for the electric grid. The use of forest biomass for energy at stationary sources can also
provide environmental benefits, such as improved soil and water quality, which help facilitate healthy
forests. Healthy forests support outdoor recreation and tourism, bringing much needed income to rural
communities. Landowners and communities benefit from the economic gains of their forests, which in
turn allows them to invest more in the habitats and ecosystems that sustain these industries. The use of
forest-derived bioenergy can also play a role in promoting domestic energy security for the U.S. and
provide flexibility for stationary sources to use a variety of feedstock resources, potentially lowering
costs. The U.S. has historically had a large forest products industry and continued growth is expected in
the bioeconomy.17 Thus, forest-derived bioenergy can provide new markets and new products to the
U.S. bioeconomy.
Currently, many U.S. states recognize the benefit of using biomass as renewable energy in their state
electricity generation mixes, as evidenced by the number of state renewable portfolio standards (RPS)
that include some biomass as an eligible renewable energy resource. Many international programs also
recognize that biomass can have benefits and encourage its use for energy production through national
energy policies, such as the United Kingdom Renewables Obligation program.18 These U.S. state and
international programs have shown that diverse energy resources and unique economic, environmental
and renewable energy goals can promote bioenergy development, as well as responsible land
management. An EPA policy treating biogenic C02 emissions from the use of biomass from managed
forests at stationary sources for energy as carbon neutral, as presented in this document, will foster the
alignment of EPA regulatory actions with the treatment of biogenic C02 emissions in U.S. state and
16 Latta, Greg S., Justin S. Baker, Robert H. Beach, Steven K. Rose, Bruce A McCarl. 2013. A multi-sector
intertemporal optimization approach to assess the GHG implications of U.S. forest and agricultural biomass
electricity expansion. Journal of Forest Economics 19 (2013) 361-383.
17 Biomass Research and Development Board. 2016. Federal Activities Report on the Bioeconomy
.
18 https://www.ofgem.gov.uk/environmental-programmes/ro
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international programs. For example, the California Cap-and-Trade Program19 and the Regional
Greenhouse Gas Initiative (RGGI)20 among Northeast and Mid-Atlantic states exempt biogenic C02
emissions from a compliance obligation, provided that specified types of biomass are used that meet
certain requirements. In addition, the European Union Emission Trading Scheme (EU ETS)21 exempts
biogenic C02 emissions at stationary sources from a compliance obligation.
Conclusion
For the reasons described above, EPA's policy in forthcoming regulatory actions will be to treat biogenic
C02 emissions resulting from the combustion of biomass from managed forests at stationary sources for
energy production as carbon neutral. Although this policy announcement does not itself alter sources'
obligations with regard to GHGs and C02 in any particular regulatory program, the Agency is committed
to addressing regulatory uncertainty about how it treats biogenic C02 emissions in forthcoming actions
under various EPA programs. The Agency also recognizes that technical, policy, legal, and Congressional
contexts may change over time and plans to revisit this treatment of biogenic C02 emissions at
stationary sources as necessary. Various tools, including data from our interagency partners, are
available to help EPA periodically assess the need to revisit this treatment in the future. For example,
the Inventory of U.S. Greenhouse Gas Emissions and Sinks can be used to track broad trends in forest
carbon stocks overtime.
EPA's policy treatment of biogenic C02 emissions associated with forest biomass use at stationary
sources for energy production aims to provide clarity to forest and forest product industry stakeholders.
As directed by Congress and Executive Orders, this policy seeks to ensure that biomass from managed
forests plays a key role in addressing the energy needs of the U.S., furthering U.S. energy dominance, in
an environmentally and economically beneficial way.
19 https://www.arb.ca.gov/cc/capandtrade/capandtrade.htm
20 https://www.rggi.org/
21 https://ec.europa.eu/clima/policies/ets_en
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