A funny thing happens when states are told to cut greenhouse gas emissions or shut down their coal plants: They start looking for solutions in unexpected places, like forests.
U.S. EPA’s draft rule to cut power sector carbon emissions suggests states could reach their targets by making coal plants more efficient, using more natural gas and renewable energy, and reducing power consumption. But it doesn’t limit them to those options.
At least two states — Georgia and Kentucky — have expressed interest in using trees as a carbon sink to offset emissions from fossil fuel plants. EPA seems to be throwing cold water on that idea, though.
That’s because forestry management programs might be valuable in offsetting greenhouse gas emissions overall, but they do nothing to reduce the pollution coming from specific power plants.
"While states have significant flexibility in the development of plans to comply with the rule, their plans must include measures that reduce CO2 emissions from affected sources: power plants," according to a statement EPA provided to ClimateWire. "As a result, the EPA did not propose that out-of-sector greenhouse gas offsets could be used by states to comply with the Clean Power Plan because these programs do not reduce emissions coming from power plant smokestacks."
Translation: Flexibility has its limits.
Studies of the southern United States have shown forests could offset about 13 percent of regional greenhouse gas emissions, Georgia’s electric regulators note in comments on the rule.
Georgia gets about a third of its power from coal, and more than two-thirds of its land is covered in forests. The state wants to be able to use those forests to comply with a federal mandate to cut its power sector emissions rate 44 percent by 2030.
"Using forests to capture and store CO2 is equivalent to using new technology to capture and store carbon directly from coal plants, while being less costly and proven to work," Georgia’s Public Service Commission said in regulatory comments. "Encouraging investment in enormous opportunities to limit carbon in our atmosphere through sequestration and offsets should be considered in the final rule."
Not a neat fit
But state officials there concede forestry programs don’t fit neatly in the Clean Power Plan.
"Trying my best to see things from the EPA’s perspective, sequestration through forestry would not lower emissions from existing generating units," said Tim Echols, a commissioner with the Georgia Public Service Commission. "The Clean Power Plan is specific to existing generating units in the electricity sector, not an economywide carbon reduction program."
John Lyons, Kentucky’s assistant secretary for climate policy who is in charge of the state’s Clean Power Plan response, got that same impression in early talks with EPA, but it didn’t stop his state from pushing for the option.
"We felt it was important to throw that out there," Lyons said.
The section of the Clean Air Act that EPA is using to write the Clean Power Plan, Section 111(d), deals specifically with stationary sources of carbon dioxide.
Rishi Garg, a lawyer and researcher with the National Regulatory Research Institute, said EPA argues the four carbon-reducing measures, or "building blocks," in the rule technically cut back on emissions from those stationary sources. But forest offsets would be different. They wouldn’t curb the amount of power needed from those sources or the subsequent emissions generated.
EPA said in the draft rule that it "anticipates — and supports — states’ commitments to a wide range of policy preferences," including states like Washington and Oregon "seeking to integrate sustainable forestry." Garg says EPA was telling states to feel free to incorporate measures outside the rule’s menu of options, "but it’s got to be convincing." And it sounds as if EPA doesn’t find this particular idea convincing.
Gloria Gonzalez, a senior carbon associate with the research group Forest Trends, says the Clean Air Act does not give EPA wiggle room on offsets; it also requires that they occur on-site, and "that’s one of the reasons that EPA is boxed in."
Other jobs for working forests
California, for example, relies heavily on forest carbon offsets for its cap-and-trade program. But Gonzalez said, "If California wants to use its cap-and-trade program … it can do that, but it has to find out a way to separate out emissions reductions generated under forestry projects.
"Those emissions reductions specifically couldn’t count toward the overall plan to meet whatever the reduction target is," she added.
Stanley Young, a spokesman for the California Air Resources Board, would not comment on what will happen to California’s forest offsets under the final rule. "The proposed rule does not allow for offsets," Young said. "We are not advocating for offsets outside of the power sector used as part of the Clean Power Plan."
Groups that advocate for private forest owners have also suggested that forest carbon offsets be allowed under the Clean Power Plan, but it appears unlikely they will aggressively advocate for the idea.
In its comments to EPA on the proposed rule, the National Alliance of Forest Owners wrote, "If used appropriately, the increased carbon benefits associated with working forests can provide states with additional flexibility to achieve EPA’s emission reduction in a low-cost manner," adding that "out-of-sector, project-based emissions offsets" could be "additional flexibility mechanisms to comply with GHG reduction goals."
However, NAFO is not pushing EPA too hard on this issue, according to the group’s president, David Tenny, and is instead focusing its attention on ensuring that emissions from biomass energy — electricity derived from burning wood — are not regulated like fossil fuel emissions under the Clean Power Plan.
Tenny said his group always advocates for markets that support private forests and is encouraging EPA to keep the option open for states. But, he added, "we try and focus our attention on things that are more tangible … and uncertainty associated with offsets in this case make it a more difficult thing to pursue."
While forest offsets are "definitely something we are thinking about," said National Association of State Foresters policy director Brent Keith, his group is also not making the issue a priority.
"The Clean Power Plan is something of a political hot potato, so it’s a little bit challenging for us to come out on one side or the other," he said.
The use of forest offsets to comply with climate regulations isn’t common outside the United States. According to Forest Trends, a nonprofit group that tracks forest carbon markets worldwide, the vast majority — 89 percent — of forest offsets purchased in 2013 were bought voluntarily, largely by big companies to meet corporate social responsibility commitments (ClimateWire, Nov. 24, 2014).
Measuring and verifying forest carbon offsets can be complicated and controversial; this is one of the reasons that one of the most widely known forest offset programs, the U.N.’s Reducing Emissions From Deforestation and Forest Degradation program, is still under development (ClimateWire, Dec. 7, 2011).
Given that so few groups in the United States are aggressively advocating for forest carbon offsets under the Clean Power Plan, it’s not likely to emerge as a major issue anytime soon.
Despite the limited parameters of the Clean Power Plan, Echols and Lyons still think states should get credit for forestry management somehow.
"Emission reductions are emissions reductions. This is a global issue. EPA’s approach to this 111(d) plan is certainly not the norm, so why not think even more outside the box and have something like that available?" Lyons said.
"Maybe Congress needs to step in and make clear that logical solutions that help solve the problem being addressed should be allowed — regardless," Echols added.
Reporter Jean Chemnick contributed.
Correction: An earlier version of this story mischaracterized what Forest Trends’ Gloria Gonzalez said about U.S. EPA and carbon offsets.