Sustainable Forest Action Coalition
542 Main St, Placerville, CA 95667
Organization Representatives
Laurel Brent-Bumb (530) 621 5885 [email protected]
Bill Wickman (530) 283 0973 [email protected]
July 14, 2010
Lisa Jackson
Administrator
Environmental Protection Agency
1200 Pennsylvania Ave., NW, Room 3426 ARN
Washington, DC 20460
Dear Administrator Jackson:
The Sustainable Forest Action Coalition is writing to express our concern and disappointment over the
EPA’s final PSD Tailoring Rule changing current proposed language in the Energy Bill to exclude biomass
combustion emissions in calculating Green House Gas Emissions.
The Sustainable Forest Action Coalition (SFAC) represents rural counties in Central and Northern
California. Our members are representatives from Amador, Butte, Calaveras, Colusa, Del Norte, El
Dorado, Lassen, Modoc, Nevada, Placer, Plumas, Sierra, Siskiyou, Shasta, Tehama, Trinity, and Tuolumne
Counties that include Supervisors, Chambers of Commerce, Fire Safe Councils, Farm Bureaus,
Agricultural Commissions, Forest Products Industry, Bio-energy Industry, Education, individual
businesses with a mix of public and private agencies and associations. SFAC covers a geographic area of
rural county’s where healthy watersheds are vital to the State of California.
The main objective of SFAC is to work at the State and Federal level to bring regulatory reform to restore
our watersheds through healthy forests while maintaining and expanding the existing forest products
and bio-energy infrastructure. By meeting this objective, the coalition also recognizes the additional
benefit that thinning to improve forest health provides to their watersheds and furthering their efforts
in protecting their natural resources from catastrophic wildfires.
Currently there are 18 biomass power plants within the SFAC area of influence with a net production
capacity of 342.4 megawatts. The supply consumption is approximately 2,739,200 bone dry tons of fuel.
In addition, there are two additional existing biomass power plants that could easily be restarted given
the right economic indicators which have a net production of 18.5 megawatts of power capacity.
We strongly encourage you to give cautious evaluation to the current arguments that have come before
Congress by 90 scientists. These scientists have stated;
"Bio-energy can reduce atmospheric carbon dioxide if land and plants are managed to take up
additional carbon dioxide beyond what they would absorb without bio-energy," the letter
says. "On the other hand, clearing or cutting forests for energy, either to burn trees directly in
power plants or to replace forests with bio-energy crops, has the net effect of releasing
otherwise sequestered carbon into the atmosphere, just like the extraction and burning of
fossil fuels.
"That creates a carbon debt, may reduce ongoing carbon uptake by the forest, and as a result
may increase net greenhouse gas emissions for an extended time period and thereby
undercut greenhouse gas reductions needed over the next several decades."
These statements are very biased and do not offer any substantial facts or figures to back their
supposed “science.” SFAC suggests you consider the following information in rebuttal to these one
sided scientific statements. After reviewing we hope you reconsider your view that biomass combustion
is truly carbon neutral, and hope that you consider this information in any further refinement of your
PSD Tailoring Rule. At least, we hope that you would consider the fact that biomass combustion is
carbon neutral in various geographic regions within the United States and that one size rules do not and
should not apply across all regions.
The most prejudice statement from the scientist letter quotes above is that the study does not and will
not apply to all geographic regions throughout the United States is;
"On the other hand, clearing or cutting forests for energy, either to burn trees directly in power
plants or to replace forests with bio-energy crops, has the net effect of releasing otherwise
sequestered carbon into the atmosphere, just like the extraction and burning of fossil fuels.”
SFAC offers you the following information to dispute these findings and to display that neither presently
or any time in the foreseeable future will their statement apply to the western United States and most
specifically to northern and central California.
If there is a concern that over clearing or cutting of forest for energy and thus lead to a net effect of
releasing otherwise sequestered carbon into the atmosphere, please consider the information in Table
1. The 17 counties that SFAC represents are dominated by National Forests lands which make up 40 to
80 percent of our total land base. Of the remaining acreage within our counties, agricultural lands
account for approximately 10-70 percent. These agricultural lands are comprised of rice, fruits, olives,
tomatoes and various other valuable crops that would not be replaced by low value bio-energy crops.
Please consider the information provided by the Forest Service, Region 5, in their 2009 Westcore Tables.
The table provides a statistical fact that within the SFAC counties; our National Forests are growing far
more forests for carbon sequestration than is managed by harvesting. You should also understand that
of the extremely low percentage of forest lands that are treated, approximately 40-60 percent of the
biomass is already being transported and utilized by the 18 biomass power plants that exist within our
geographic region.
FOREST
Productive
Forestland
(Acres)
El Dorado
Klamath
393,498
966,749
Table 1. National Forest Growth, Mortality
and Percentage of Growth Sold in 2009
Annual
Av Annual
Mortality
2009 Vol
Net
Mortality
as % of
Sold
Growth
(mmbf)
net
(mmbf)
(mmbf)
growth
198.2
50.1
26%
26.02
125.7
90.1
72%
50.06
As % of net
growth
13.1%
39.8%
Lassen
Modoc
Plumas
ShastaTrinity
Six Rivers
Stanislaus
Tahoe
TOTAL
860,680
570,754
988,969
1,056,859
266.2
84.4
1,134
459.7
105.5
40.0
66.5
99.4
36%
42%
6%
21%
69.4
32.13
33.77
12.07
26.1%
38.1%
3%
2.6%
621,302
385,691
669,910
6,514,412
219.0
181.9
535.1
3,204.2
71.7
41.9
41.7
606.9
33%
23%
8%
18.9%
11.43
29.86
28.74
293.48
5.2%
16.4%
5.4%
9.2%
Table 1 data is from the National Forests within the geographic region represented by SFAC, and it
shows that less than 10 percent of annual net growth of forest on these National Forest land is actually
treated and removed. If these lands were properly managed, a large percentage of the 18.9 percent of
annual net growth that is lost to mortality each year could be available for biomass energy and still have
over 70 percent of the annual growth available for carbon sequestration. This data and information
overwhelmingly contradict the statement quoted above and the panic message that you seem to be
reacting to by 90 scientists.
In addition to this information, the situation in the vast majority of the Western United States ignored or
missed in the scientist letter is the fact that the most critical issue is related to catastrophic wildfires. If
these scientists as well as your staff who developed the PSD Tailoring Rule were really concerned about
the carbon issue, you would take into consideration the tremendous amount of carbon dioxide that is
released when these under managed forests burn up each year. Please consider the following
information in relation to this fact.
Since the start of the 2001 National Fire Plan, Californian’s have suffered through three new state
records with 1.0 million acres burned in 2003, 1.5 million acres burned in 2007 and our latest state
record of 1.6 million acres burned in 2008. Furthermore, a new 75-year national record was set by the
2006 fire season. During the summer of 2008, while most of Northern California was enveloped in a
smoke cloud from mid-June to the beginning of August, the Northern Sierras were experiencing the
largest fires in their history. Furthermore, in 2009, Northern California lost approximately 500,000 acres
to wildfire In addition to the direct threat to public health and safety; these large catastrophic fires are
also destroying the forests that are needed for carbon sequestration. Often the Forest Service, for a
variety of reasons, is not able to reforest these lands and they type convert to brushfields, which
sequester far less carbon dioxide than a healthy forest. These fires are also degrading the watersheds
that are the prime source of California’s domestic and agricultural water supply.
Another factor that the PSD Tailoring Rule ignores is something that President Obama has continually
discussed and supported and that is providing jobs in areas with high unemployment. Many of our 17
counties are presently experiencing unemployment rates well into the 20-30 percent range.
In 2009, three of our counties were impacted with three mill closures. These three facilities are a
combination of biomass energy facilities as well as forest product manufacturers. Within these three
counties, we lost approximately 450 direct jobs. It is not only these immediate direct job losses, but the
additional 1.6-2.25 associated indirect and induced jobs for every 1 direct job within our business
communities that causes dramatic loss in local community stability. This recent loss of our remaining
forest products infrastructure is the latest round of closures that have occurred in our counties since
1989.
This loss of infrastructure in these three counties, El Dorado, Plumas and Tuolumne, have made it even
more difficult to accomplish needed vegetation treatments that are vital to our watershed health as well
as reducing the ever-increasing threat of large wildfire. Without the wood products infrastructure,
there is no financial means to remove the surface and ladder fuels that provide the feedstock for the
biomass power plants. Biomass treatment within our forests is not an economical product by
themselves. Biomass treatment must be supplemented by either adding value through sawlog
treatment and removal or by the expenditure of additional dollars. Recently the state has endured some
of the worst fire seasons in recorded history.
When discussing losing the existing forest products infrastructure, it is important to consider what these
jobs mean to our rural economic and social well-being. Forest workers and the related jobs that this
infrastructure provide are all family wage jobs that provide health and insurance benefits. We
encourage you to consider how to increase the needed acres treated to restore, enhance and stabilize
our county’s natural resources and forest products infrastructure. With the emphasis on job creation,
nationally, the following information should be used to highlight the importance of this effort to
revitalize and maintain this economic opportunity.
The harvest and forest health treatments on National Forests within our Counties had an annual harvest
that has been reduced to approximately one sixth of our historical levels of the late 1980’s and early
1990’s. This is a result of current laws, regulations and litigation. When looking at forest related jobs
and economics, 1 million board feet of harvest equates to 11.4 new direct and indirect jobs with an
average annual wage of $43,200 per job. We are sure this is low for California, but those statistics were
from Oregon Department of Forestry. Also statistics from the US Agriculture Department showed that
for every $1 million invested in forestry projects 39.7 jobs were created.
What have our rural forested counties lost as far as forest products infrastructure over the last 10-20
years? The following table will outline this loss over the last 20 years by county. These are the counties
that SFAC represents within the Sierra Nevada Province;
COUNTY
Amador
Butte
Calaveras
El Dorado
Lassen
Modoc
Nevada
Placer
Plumas
Shasta
Sierra
Mills Closed
1989-1999
2
1
1
2
2
4
1
2
2
10
0
Table 2. Mill Closure from 1989-2009
And Mills Open by County in 2010
Mills Closed 2000- Mills
2009
Remaining
0
1
0
1
0
0
2
0
2
0
0
0
0
0
0
2
(small log mill)*
2
3
6
1
0
Biomass & Sawmill
Combination Closed
1 (20MW)
1 (11 MW)
1 (4.5 MW)
Siskiyou
4
1
3
Tehama
5
0
0
Trinity
1
0
1
1 (11MW)
Tuolumne
1
1
1
Yuba
3
1
0
TOTAL
41
12
17
*SPI Quincy closed their small log mill in 2009 which is a part of the combination of small and large log
facility. SPI has recently stated they plan to reopen the small log mill with two shifts of operation but
are curtailing one shift in the large log mill.
The column, Biomass and Sawmill Combination Closed in Table 2, indicates the number of forest
products facilities that were a sawmill that also had a biomass energy facility co-located to produce
energy from the mill waste as well as supplemental chip supply from forest thinning. This is another
point that the Scientist letter ignores when they indicate that the bio-energy industry will only lead to
the loss of forests that provide the positive carbon sequestration benefit. In reality what our member
counties have already lost is a tremendous bio-enery production capability and will only loose more if
the current PSD Tailoring Rule does not recognize that this industry does have a carbon neutral effect.
The stand alone, as well as co-located bio-energy facilities is actually a positive factor in the reduction of
green house gases.
SFAC members implore you to consider the information that we have provided. It is critical that EPA
research the true benefits of bio-energy and all of the positive effects that it provides when you are
discussion the reduction of green house gases. If we can provide you further information that would
assist you in your evaluation, please contact us. Thank you for your consideration.
Sincerely,
and
Bill Wickman and Laurel Brent-Bumb
Representatives for the Sustainable Forest Action Coalition
Enclosure:
Jobs Created per $1 million investment by sector in the economy
Cc:
Senator Feinstein
Congressman Herger
Congressman McClintock
Congressman Lungren
Congressman Radanovich
State Senator Cox
State Senator Aanestad
State Senator Cogdill
Assemblyman Berryhill
Assemblyman Logue
Assemblyman Nielsen
Bill Connelly, Butte County Supervisor
Gary Evans, Colusa County Supervisor
Ray Nutting, El Dorado County Supervisor
Lloyd Keefer, Lassen County Supervisor
Sean Curtis, Modoc County Farm Bureau
John Spencer, Nevada County Supervisor
Jim Holmes, Placer County Supervisor
Lori Simpson and Sherrie Thrall, Plumas County Supervisor
Linda Hartman and Leonard Moty, Shasta County Supervisors
Bill Nunes, Sierra County Supervisor
Tim Beals, Sierra County
Marcia Armstrong, Siskiyou County Supervisor
Roger Jaegel, Dero Forslund and Jim French, Trinity County Supervisor
Teri Murrison and Dick Pland Tuolumne County Supervisor
Steve Brink, California Forestry Association
Frank Stewart, QLG County Forester
Tom Partin, American Forest Resource Council
Bob Kingman, Sierra Nevada Conservancy
Bill Renfroe, Del Norte Tri-Agency Economic Development Authority
Dale Walters, Director, Cal Fire
Lester A. Snow, Secretary, Natural Resources Agency
Meg Whitman, Republican Candidate for Governor of California