Robert e. gay sr. column proposed virginia deq forest biomass regulation must reflect carbon reality their opinion richmond.com electricity video bill nye

Virginia is a leader in developing an innovative and diverse energy marketplace to ensure the state’s economy will remain competitive well into the future. However, a new regulation being developed by the Department of Environmental Quality could create an unprecedented threat to one of the pillars of Virginia’s energy future.

Forest biomass powers Virginia’s economy. More than 27,000 Virginians make a living in the commonwealth’s forestry and forest products industry, which includes manufacturers of pulp, paper, packaging, tissue, and wood products. They make nearly $7.4 billion in products, earn a total payroll of almost $1.5 billion a year, and generate annual state and local tax revenue of $155 million. Forest biomass also powers many of the facilities in which this economic activity takes place.

Paper and wood products mills in Virginia and around the country use forest biomass residuals from their manufacturing processes to power their operations, reducing their need to purchase electricity from the grid and making use of material that could otherwise be sent to landfill. Power generated throughout that process does not contribute to the buildup of greenhouse gases in the atmosphere. According to research in the Journal of Industrial Ecology, using residuals this way produces a greenhouse gas reduction benefit over a single year equal to removing 1 million cars from the road.

Consistent with the United Nations’ Kyoto Protocol and the policies of other nations around the world, biomass energy should be considered carbon neutral [in Virginia]. Data from the U.S. Forest Service indicate that timberlands in Virginia grew more than twice as much wood as was harvested in 2016 — wood that is sequestering carbon — while the U.S. as a whole also grew nearly twice as much wood as was harvested. These sustainable manufacturing practices should be rewarded, not penalized. Virginia’s manufacturing facilities are competing with companies in Europe and elsewhere, and the biomass energy of those competitors is recognized as carbon neutral and, in some cases, handsomely rewarded.

Virginia’s DEQ seems to be moving in the opposite direction. A draft regulation from the DEQ’s Air Pollution Control Board would, for the first time in any state, classify an electric generating facility as fossil fuel-fired and subject to additional regulations if just over 10 percent of the fuel mix it uses is fossil fuel and the remainder is forest biomass.

This approach is not supported by science, is inconsistent with the model rule of the Regional Greenhouse Gas Initiative (RGGI), which is what prompted this regulation in the first place, and would set a dangerous precedent for other states considering how best to support carbon-neutral energy.

Forest biomass residuals sometimes are mixed with small amounts of fossil fuels, but research shows that mix does not change the carbon profile of the biomass. The physical and life cycle characteristics of the biomass remain the same regardless of whether or not it is co-fired with a fossil fuel — thus, the 10 percent threshold is entirely arbitrary.

DEQ can and should do better by using a science-based approach that acknowledges the real-world attributes of forest biomass and its contribution to carbon-neutral power generation. The proposed regulation should be updated to reflect the reality that the carbon profile of biomass has no credible connection to the amount of fossil fuels that may or may not be fired in the same generator. The proposed regulation can be improved further by removing language stipulating that Virginia join RGGI — a legislative question, not a regulatory one. Also, the proposed regulation should indicate clearly that the DEQ maintains the current exemption for industrial boilers.

The forest products industry is a top 10 manufacturing sector employer in 45 states, meaning thousands of facilities across the country are generating carbon-neutral power by using forest biomass residuals. As a recognized leader on energy policy, Virginia can use this regulatory process to set a clear, science-based standard other states can follow: Forest biomass is an important carbon-neutral and renewable source of power that supports a vibrant manufacturing sector.