Greenhouse Gas Regulation

AF&PA members have reduced their greenhouse gas (GHG) emissions intensity by over 23 percent since 2000. Beyond what the industry has already achieved, we have committed to a reduction of at least 15 percent by 2020 from a 2005 baseline.

Federal, regional and state climate change policies and programs are being considered or implemented across our nation to address GHG emissions. These policies must balance environmental, social and economic concerns to ensure that our nation’s economy and the paper and wood products industry remain globally competitive. Policies should also 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.

GHG regulations should ensure least cost compliance and electricity reliability.

The Clean Power Plan (CPP), which regulates GHG emissions from existing electric utilities under the Clean Air Act (CAA), affects all users of electricity. We are concerned the CPP seeks emissions reductions that are beyond the U.S Environmental Protection Agency’s legal authority and that could increase our energy costs, decrease the reliability of the electric system, and set adverse precedent for potential GHG regulation of our industry. AF&PA members spent over $7 billion on electricity and natural gas in 2013. Because we operate in a highly competitive global market, increases in our energy costs can significantly harm the competitiveness of our industry. Further, reliable electricity is critical for manufacturing operations. While EPA claims it has addressed reliability concerns, the nation’s experts on electricity reliability have determined that the CPP does not adequately resolved those concerns. 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.

GHG regulations must recognize the carbon neutrality of biomass energy.

Our industry’s products and how we produce and use biomass energy are all part of the sustainable carbon cycle. Although EPA acknowledges that biomass energy can have climate benefits compared to using fossil fuels, EPA’s 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. However, our industry needs greater certainty regarding the carbon neutrality for all manufacturing residuals and “sustainably-derived biomass.”

The use of biomass for energy production is not the same as burning fossil fuels or purchasing fossil fuel-based electricity, and policymakers should provide certainty regarding the carbon neutrality of the biomass energy produced and used by the forest products industry in all current and proposed GHG regulations.