Dear Administrator Pruitt:
Electricity derived from renewable biomass is an important source of carbon neutral power that is reliable, supports jobs, and contributes to healthy farms, forests and municipal infrastructure. For these reasons, we urge your Agency to take quick action in the processing of biomass and waste-to-energy pathways submitted under the Renewable Fuel Standard, and to resolve any outstanding programmatic issues that stand in the way of allowing these sources of energy to receive the same support afforded other forms of energy.
Approving and registering biomass-derived electricity is important to our state and consistent with your message in Manchester, New Hampshire earlier this year when you voiced your support for biomass and also in your recent announcement of EPA's consideration of biomass as a carbon neutral source of energy. Biomass is an important component of our state's forest products economy, providing markets for low-value organic material that would otherwise be discarded or landfilled.
Biomass is especially critical to the state of California. Our state is experiencing an unprecedented tree mortality crisis, with an estimated 129 million dead or dying trees statewide, according to the U.S. Forest Service. As users of low-value wood fibers, biomass power facilities are an important component of forest management, enabling the productive and environmentally sound use of debris cleared out of forests to reduce forest fire risk. Unfortunately, the biomass power industry in our state is experiencing its own difficulties, with over half the fleet currently idled due to a transformed power market partially due to lopsided federal support for other renewables like wind and solar. California has enacted the BioRAM policy requiring utilities to purchase a certain amount of biomass power, which has been helpful -- but EPA action approving the qualification of biomass power under the RFS is sorely needed to keep these facilities online and contributing to ongoing forest management and fire prevention efforts.
While it is appropriate to carefully review the overall RFS program, we are concerned that EPA's inability to process the registrations of biomass-derived electricity has created "winners and losers" among agricultural fuels and their feedstocks. Corn ethanol producers in many states have benefitted tremendously from the Renewable Fuel Standard -- and our biomass power producers in California should be able to participate as well.
Allowing biomass power to qualify and register under the RFS will help ensure a stable future for California biomass power producers, preserving and creating jobs in rural areas where they are most needed. We urge you to act as soon as possible on the petitions and registrations before you, enabling biomass power and waste-to-energy to qualify to produce RIN credits.