Office of the Administrator 1101A
U.S. Environmental Protection Agency
1200 Pennsylvania Ave., N.W.
Washington, DC 20460
Dear Administrator McCarthy:
We are a group of conservationists, faith leaders, sportsmen, and residents in the Southern US who are writing to express our deep concern that EPA’s final rule on biomass under the Clean Power Plan (CPP) threatens our forests and quality of life. We are very concerned about the direction EPA has taken on this issue and the potential it has to accelerate the destruction of southern US forests – with implications in all forested regions within the US. We need to be better stewards of the land and its resources. Burning forests for electricity is not a sustainable solution for meeting global energy demands. In fact, treating biomass as carbon-neutral would produce a 70% increase in the U.S. wood harvest, consuming more than four times as many trees as Americans save through paper recycling programs.
Here in the South, we understand the consequences of government policies that encourage the use of forests for fuel. Due to similar flawed policies in Europe, in just the past 3 years the Southern US has become the world’s largest wood pellet exporter. It has been well documented that the production of these wood pellets from our forests is driving an increase in logging, including in ecologically sensitive habitats such as coastal wetland forests. If this trend continues, according to the USFS, even more of the South’s natural forests will be destroyed to make way for fast growing pine-tree plantations. Pine plantations contain about 90-95% less biodiversity than our native forests.
Our living natural forests provide many benefits. Standing natural forests not only remove and store carbon from the atmosphere, they also provide our communities with clean air to breathe, water to drink and natural protection from flooding and hurricanes. They are home to countless species of plants and animals found nowhere else on earth. They are the places in which families gather and commune with the natural world. They are heritage hunting and fishing grounds for current and future generations of Southern outdoorsman.
Destroying these forests for fuel to generate electricity is bad policy. Instead, we need sound CPP implementation plans that drive greater investments in the protection of forests for their water, wildlife and climate benefits. We need policies that support and encourage forest landowners to maintain forest cover and manage natural forests for these critical services that benefit us all.
The scale and rate of logging in the Southern US is already of concern. Southern forests are already a resource under stress, providing the lion’s share of the wood and paper products we all use. The South has already lost tens of millions of acres of forests to pine plantations. Over decades, this practice has disrupted natural forest cover at such a scale that entire ecosystems are now at the brink of extinction (i.e. the longleaf pine forest), and entire watersheds have been altered (such as the Waccamaw River Basin.)
As it currently stands, EPA’s final rule will lead to Federal and State implementation plans that rapidly accelerate these trends at a time when we all need to be rallying together to reverse them. Our forests are simply too valuable to be destroyed and burned to generate electricity, especially when there are better, more efficient and feasible alternatives.
We want energy solutions that don’t incentivize forest destruction. We want policy that doesn’t sacrifice our communities and cultural traditions for a false solution. We ask EPA to heed the advice of tens of thousands of citizens and fully recognize the negative impacts of incentivizing the use of forests as a fuel source for generating of power. We don’t want the Southern US to become a region that destroys its forests and the health of its communities in the name of green energy.
For Our Forests,
Alabama Coast United
Alabama Energy Doctors
Alabama Rivers Association
Fairhope Unitarian Fellowship
MEJAC (Mobile Environmental Justice Action Coalition)
NACK (North Alabama Canoe and Kayak)
Open Table: A Community of Faith (United Church of Christ) in Mobile
Solar Technology Alabama
Bay County Audubon Society
Green Sanctuary Committee of the UU
Congregation of Venice
Florida Clean Water Network
Florida Wildflower Foundation
NW FL Defenders of Wildlife
Sunshine State Interfaith Power and Light
UCC of St. Augustine
Unitarian Universalist Justice Florida
UU Church in the Pines
The Rev. Dr. Russell L. Meyer, Executive Director, Florida Council of Churches
Georgia Interfaith Power & Light, Inc (GIPL)
Rev. Anthony Makar, Senior Minister, Unitarian Universalist Congregation of Atlanta
Gulf Restoration Network
Joule Solar Energy
Louisiana Purchase Cypress Legacy
North Mississippi Allstars
Carolina Mountain Club
Clean Air Carolina
Community United Church of Christ Justice in a Changing Climate task force
Medical Advocates for Healthy Air
NC Interfaith Power and Light
Rev. Douglas S. Long, Umstead Park UCC, Raleigh, NC
Sundance Power Systems
UU Justice Ministry of North Carolina
Backpacker Quality Gear Inc.
Brookemeade Congregational UCC
Tennessee Interfaith Power & Light
Arlingtonians for a Clean Environment
Chesapeake Climate Action Network
Roanoke Outdoor and Social Club
UU Legislative Ministry of Virginia
Mountain High Hikers, Inc.
Unitarian Universalist Ministry for Earth
Sarah Dunham, EPA Office of Atmospheric Programs
Janet McCabe, EPA Office of Air and Radiation
Bill Irving, EPA Climate Policy Branch
Alllen Fawcett, EPA Climate Economics Branch