Greenhouse Gas Regulation
Between 2005 and 2014, AF&PA members reduced their greenhouse gas (GHG) emissions by 16 percent, surpassing our Better Practices, Better Planet 2020 goal of 15 percent reduction.
In 2017, wanting to further improve their performance, members launched a new goal to achieve a 20 percent reduction of GHG emissions by 2020 from the 2005 baseline.
U.S. fossil fuel and industrial process emissions declined 12 percent between 2007 and 2015, largely due to market driven and voluntary reductions such as improved energy efficiency and shifts from coal to natural gas by the electric utility sector. During that same period, global emissions increased by 13 percent, and China’s rose 42 percent, according to data compiled by the European Commission. Policymakers should recognize that market driven, voluntary reductions can make burdensome regulations unnecessary.
Nonetheless, some regional and state government policies are being considered or implemented across our nation to reduce GHG emissions. These policies must balance environmental, social and economic concerns to ensure that our nation’s economy and that the paper and wood products industry remain globally competitive. They also should recognize the industry’s unique role and early actions to reduce GHGs, including the efficient production and use of large quantities of carbon-neutral biomass energy, sustainable forest management and procurement practices, carbon sequestration, electricity generation and paper recycling.
Policymakers should reassess the need for GHG regulations in light of ongoing, market-driven GHG reductions, and any regulations should ensure least cost compliance and electricity reliability.
The Clean Power Plan (CPP) federal regulation of GHG emissions from existing electric utilities under the Clean Air Act (CAA) was stayed by the Supreme Court in February 2016. The stay removes the states’ obligation to submit compliance plans to EPA until after litigation is resolved.
We are concerned the CPP seeks emissions reductions that are beyond the U.S. Environmental Protection Agency’s legal authority and could increase our energy costs, decrease the reliability of the electric system and set adverse precedent for potential GHG regulation of our industry. The forest products industry manufacturing sector spent over $9 billion on electricity and purchased fuels in 2015.
Because we operate in a highly competitive global market, increases to our energy costs can significantly harm the competitiveness of our industry and harm our ability to provide high- paying manufacturing jobs in the many rural communities in which we operate. In addition, AF&PA is concerned about the potential adverse precedent that could be set if the final rule retains the “beyond the fence line” measures that seek emission reductions at unreasonable costs and at the expense of reliability. In light of all these flaws, AF&PA supports the EPA’s recent proposal to repeal the CPP pursuant to the president’s Executive Order and the D.C. Circuit’s Order to hold in abeyance the litigation challenging the rule. We also support EPA’s action soliciting information on a potential CPP replacement.
Some states are continuing to develop and implement greenhouse gas reduction plans. AF&PA believes states should not move forward with greenhouse gas regulations until the administration’s reconsideration process and CPP litigation is resolved. Any states that nonetheless do move forward should ensure they are adopting least-cost approaches.
Forest Products Industry’s Use of Biomass Should Be Recognized as Carbon Neutral
Our industry’s production and use of biomass energy are all part of the sustainable carbon cycle. We encourage EPA, working with the Departments of Agriculture and Energy, to rely on the recently-enacted appropriations legislation to establish clear and consistent policies reflecting the carbon neutrality of forest-derived bioenergy. Although EPA acknowledges that biomass energy can have positive climate benefits, the CPP sets up significant hurdles for states to qualify their use of biomass energy as a compliance measure.
In addition, EPA’s revised accounting framework for biogenic carbon dioxide emissions and the accompanying policy guidance released in November 2014 acknowledge the carbon benefits from certain forest products manufacturing residuals. After years of consideration (2011 to present), EPA has not provided the regulatory certainty required for the forest products industry by ensuring that its biomass energy is considered carbon neutral.
Legislation enacted in May 2017 provided direction to the administration for clarifying biomass carbon neutrality. Our industry is the leading producer and user of biomass energy, with about two-thirds of our power generated from forest-based, renewable biomass, and we urge EPA, USDA and DOE to implement the legislation as soon as possible to provide regulatory clarity.