Comment Details
| Comment Author: | Llewellyn Matthews |
| Organization: | Northwest Pulp and Paper Association |
| Comment Date: | Thursday, 04 June 2009 |
| Comments: |
Cover Letter: June 4, 2009 Mr. Jim North, Chair Western Climate Initiative Reporting Committee www.westernclimateinitiative.org Subject: Northwest Pulp and Paper Association Comments on the Draft Western Climate Initiative “Draft Essential Requirements of Mandatory Reporting (May 7, 2009)” Dear Mr. North and WCI Partners: Northwest Pulp and Paper Association represents the pulp and paper mills in the states of Washington, Oregon and Idaho. Pulp and paper mills are both large energy intensive industries and also generate a very high rate of their own energy needs from renewable biomass sources. Our mills range from 65-85% energy self-sufficiency from biomass sources. NWPPA members expect to be encompassed in state programs aimed at reducing greenhouse gas emissions from stationary sources. NWPPA members support goals of obtaining accurate credible reporting of greenhouse gases and we expect the majority of our C02 emissions from biomass and fossil fuel combustion will be encompassed within either a federal or state reporting program. NWPPA appreciates this opportunity to comment on the second draft of essential reporting requirements and wish to thank-you for improvements over the first draft released in February. NWPPA has some significant science and policy concerns that were not addressed in the revision process and wish to go on record that these concerns remain major concerns. NWPPA shares the concerns raised by AF&PA and incorporate their letter by reference. NWPPA thanks the WCI partners for agreeing to accept additional comments within a reasonable period after the June 4th deadline. Both AF&&PA and NWPPA may be submitting additional comments. The purpose of this letter is to address our major concern: Biomass Carbon (CO2) Neutrality Is A Scientific Principle; Not A Policy Principle, And Should Be Treated as Such for All WCI Purposes 1. Biomass Carbon neutrality is a function of the biogenic carbon cycle Biomass carbon neutrality derives from the scientific nature of the biogenic carbon cycle, as it exists on our earth. The biogenic carbon cycle involves the cycling of the same quantity of CO2 molecules and carbon molecules that are associated with biomass sources in recent times (as opposed to carbon deposited in geological time frames). CO2 is removed from the atmosphere during photosynthesis and stored in plants as organic carbon (sequestered) until it is released again as CO2 through combustion, or decomposition. Biogenic CO2 is always carbon neutral regardless of where it is in the carbon cycle. This is true regardless of how much biogenic CO2 resides at a particular point in the carbon cycle. To illustrate, consider two unlikely extremes. First, the earth could be completely vegetated, with the vast majority of the CO2 sequestered. Secondly, extreme events such as catastrophic fire or a meteor strike could result in the release of vast quantities of CO2. Both are carbon neutral because it is the same carbon, but what changed is where the majority of the carbon is in the cycle. Biomass neutrality derives from the fact of recycling the same quantity of CO2 that has been present in recent times, rather than release of new quantities of CO2 from fossil fuel. This principle is recognized in the international community. Policy makers such as WCI are legitimately concerned about how humans engage in the carbon cycle, but these concerns give rise to different and entirely independent questions. These include questions regarding whether biomass is grown sustainably and how we wish to govern our behavior. The scientific principle and policy objectives should not be confused as WCI is putting forth. Following this logic, NWPPA believes the WCI made a fundamental error in the WCI “Final Design Recommendations for the Regional Cap and Trade Program (September 2008)” whereby each jurisdiction is left to determine the eligibility criteria for biomass to be considered carbon neutral. WCI furthers this scientific error in the “Response to Stakeholder Comments and final Draft Essential Requirements of Mandatory Reporting (May 7, 2009),” in the discussion of biomass in thresholds (pages 4-5). WCI should not be suggesting that it is state discretion to refine or re-characterize scientific principles. This makes no more sense than leaving to state discretion definitions of the water evaporation cycle, laws of thermodynamics or gravity. What does make sense is to direct our efforts to understanding whether or not biomass is sustainability grown and used, as discussed further in these comments and in greater detail by AF&PA. 2. The proposed reporting requirements perpetuate a confused concept of the biogenic carbon cycle, and could actually impair energy efficiency objectives. The applicability section (WCI.1) allows jurisdictions to make determinations regarding the carbon neutrality of biomass emissions for exclusions and applicability of the thresholds. As explained above, WCI should not be suggesting that jurisdictions make determinations as to carbon neutrality of biomass emissions because: • There is no legitimate role in the legal arena in re-defining or altering recognized scientific principles. Jurisdictions have no guidelines or principles to do so and will generate confusion more intra-regional discrepancies and possibly competitive disadvantages within WCI jurisdictions. It certainly produces a competitive disadvantage relative to the international community that recognizes established scientific principles. • Jurisdictions may attempt to describe carbon neutrality of biomass emissions that may create conflicts of law within that jurisdiction if the jurisdiction has laws and regulations already (and all within WCI apparently do) that address sustainability of forest practices. WCI’s approach in effect encourages a back-door method of affecting existing laws and regulations governing forest practices. • Jurisdictions are unlikely to be able to effectively address whether or not certain biomass fuels were sustainably grown but the highest and best use of them may be as fuel in certain circumstances. WCI’s approach would impair such beneficial uses. Examples: o Urban wood that is clean enough to use as fuel (no paint, etc) may be old and of unknown origin. If a jurisdiction declared such wood “not carbon neutral” because it is unknown whether the forest practices that produced it were sustainable practices, the result may be land filling. The wood would deteriorate slowly over time releasing its CO2 (perhaps methane as well). The C02 will ultimately be released regardless, but without beneficial energy value. o Catastrophic local floods may equally damage areas where sustainable forest practices were employed and areas where they were not. The excess debris from such events, if declared “not carbon neutral,” might again be left to decompose, releasing CO2 to the atmosphere without beneficial energy value • Lastly, consider a practical reality: most jurisdictions will know which biomass was sustainably produced and most bio-energy producers want to use sustainably produced biomass. However, for some small amounts of biomass, when separated from the land (urban wood for example) there may never be enough information to understand whether or not it was sustainably produced. Nor can we reach back in time and alter how it was grown, but we can look forward and obtain the best use of it, which may include being used as biomass fuel. If so, it is useful in displacing fossil fuel consumption. 3. How Might WCI Correct This Error NWPPA appreciates the intent WCI expresses in the response to stakeholders that it is trying to alleviate the burden on small facilities burning pure biomass. While helpful, this does not address the fundamental flaw that the pulp and paper/forest products industry has identified in WCI’s scientific understanding. NWPPA respectfully suggests that WCI should make the effort to go back to the drawing board and start over, starting with the principle that all C02 from biomass emissions is carbon neutral. Then WCI should identify a series of options for jurisdictions to consider addressing concerns regarding sustainability concerns; suitable biomass, etc. However, WCI should encourage jurisdictions to address these concerns through appropriate forest and land based practices. Our industry would welcome the opportunity engage in an actual dialog with WCI and to work with WCI on such an effort. Sincerely, Llewellyn Matthews, Executive Director CC. WCI Partners |