September 17, 2015

Gina McCarthy


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

Choctawhatchee Riverkeeper

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)

Hike Georgia

Rev. Anthony Makar, Senior Minister, Unitarian Universalist Congregation of Atlanta



Gulf Restoration Network

Joule Solar Energy

Louisiana Purchase Cypress Legacy



North Mississippi Allstars


North Carolina

Carolina Mountain Club

Clean Air Carolina

Community United Church of Christ Justice in a Changing Climate task force

Dogwood Alliance

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


South Carolina

Backpacker Quality Gear Inc.



Brookemeade Congregational UCC

Tennessee Interfaith Power & Light



Arlingtonians for a Clean Environment

Blackriver/Nottoway Riverkeeper

Chesapeake Climate Action Network

Roanoke Outdoor and Social Club

Virginia Organizing

Wild Virginia

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