FRA’s 2018 Policy Priorities

The U.S. wood supply system is the largest and most highly developed in the world, providing the raw material that furnishes our country’s seventh largest industrial sector:  forest products.  Overregulation threatens this system’s ability to continue to serve both its economic and environmental goals in a sustainable manner, especially in view of the large role small business plays in this system’s function and management.  FRA monitors and engages public policy processes that impose unreasonable costs and overly burdensome processes on the wood supply chain or that impede sensible reforms that might enhance competitiveness.

Paralysis by overregulation places in jeopardy the livelihoods of mills, employees, and dependent communities; harvesting and forest operations contractors and their employees; and the ten million private, institutional, and industrial forest landowners that support its resource base.  In the end, a dysfunctional wood supply system would not only be economically devastating but would expose the forest resource to wildfire and disease, leaving watersheds and wildlife habitat vulnerable and compromising the character of our country’s landscape.

What is overregulation?  The intrusion of government into the management of private business to an extent not justified by the duty to promote the general welfare or to achieve transparency in exercising that duty.

Under Attack: Biomass Carbon Accounting

Impact:  Federal carbon policy’s failure to acknowledge the principle of carbon neutrality in diverting woody biomass to energy production would obstruct U.S. energy policy’s potential for reducing total carbon emissions and make both established and emerging biomass energy conversion technologies uncompetitive.

The Issue: Interests that oppose biomass as a fuel source for generating energy have been attacking the environmental attributes of forest-based biomass. Specifically, activists are alleging that biomass combustion emits more carbon to the atmosphere than burning coal does. The attacks cite flawed studies, such as the Manomet report that the Partnership for Policy Integrity published in 2010. In essence, that study took a siloed view of the forest resource, ignoring the larger carbon cycling dynamic that occurs across working forest landscapes. Such attacks on biomass for energy projects have continued as export pellet mills have proliferated in the U.S. South.

FRA advocates public policies recognizing forest-based biomass energy as carbon-neutral, sustainable, and renewable. FRA’s advocacy with respect to greenhouse gas emissions reduction policy at the federal level focuses entirely on defending the well-validated principle of biomass carbon neutrality and its basic role in forest products’ contribution to sustainable forestry. FRA has no position on “climate change” as a policy issue, confining itself to advocating that any policies addressing climate change respect the principle of the carbon neutrality of forest biomass and the science that supports it.

Status: In August 2015, the U.S. Environmental Protection Agency unveiled its final Clean Power Plan (CPP), the Obama Administration’s comprehensive regulatory approach to limiting carbon emissions from coal-fired electric utilities. The final rule addresses biomass and its potential for contributing to the goals of the CPP; however, it does not outline definitive policy on forest-based biomass energy and leaves a number of questions regarding biomass energy open to public comment via a proposed Federal Plan that accompanied release of the final rules. On January 21, 2016, FRA submitted comments on this proposed Federal Plan, which EPA indicates will serve as a model for states to use in crafting their own plans or will become the enforcing document in instances where states fail to submit their own plans.

On February 9, 2016, the U.S. Supreme Court stayed implementation of the Clean Power Plan pending the outcome of related cases before the U.S Court of Appeals. At that time, it appeared that the CPP was destined to be overturned, given that the Supreme Court took the unusual move of staying the rule. However, with the passing of Justice Scalia, the path forward for this rulemaking is anything but clear.

On February 2, 2016, the full Senate approved an amendment to the Energy Bill (S 2012) instructing federal agencies to ensure that federal policies fully recognize the carbon neutrality of forest-based biomass energy; and the full Senate passed the Energy Bill on April 20, with the amendment included; a conference to reconcile the Senate Energy Bill with a corresponding House bill is not yet scheduled. On June 16, the Senate Appropriations Committee approved the FY 2017 Interior Appropriations Bill establishing even stronger guarantees that federal agencies not regulate CO2 emissions from forest biomass energy-generation processes, as long as the Forest Inventory & Analysis program affirms steady or growing carbon stocks, with reference to established baselines. The House Interior Appropriations bill, passed June 15, also contains favorable “carbon neutrality” terms. Both bills must still pass floor votes, probably following the November 8 Election.