Virginia Forestry Association

3808 Augusta Avenue

Richmond, VA  23230

804-278-8733

August 24, 2018

RE: 2018 Virginia Energy Plan

I am writing on behalf of the Virginia Forestry Association to provide comments on the 2018 Virginia Energy Plan.  VFA represents Virginia’s diverse forestry community and promotes the sustainable use and conservation of forest resources to ensure their long term social benefits for all Virginians.  Our 1200 members include a vast array of forest product businesses, woodland owners, and forestry professionals.  We believe that the conservation and sustainable use of forest resources drive ecological, economic, and social prosperity in Virginia.

We believe that Virginia’s 2018 Energy Plan must recognize the essential role that biomass plays in the marketplace.  Virginia’s forestry community, the Commonwealth’s third largest economic sector, relies on biomass not only to generate much of its power, but also to provide a critical secondary market for manufacturing residuals that have no higher and better use. 

The forest products industry is the largest producer and user of bioenergy of any U.S. industrial sector. The responsible use of biomass energy in forest product mills is fundamental to the manufacture of its products and while biomass accounts for a small portion of the Commonwealths’ current utility-scale energy generation, it comprises an important component of its baseload energy mix.   

Biomass is a true renewable fuel source, especially as the broad adoption of sustainable forestry practices has led to a dramatic resurgence of Virginia’s forestland.  Today, 62 percent of Virginia is forested which is more than at the time of the Civil War.  In 2014, the ratio of the forest’s annual growth compared to harvest volume on private and state lands was more than 2.1:1 for softwood species and 2.2:1 for hardwood species. This amounts to an annual surplus of 8.4 million tons of softwood and 14 million tons of hardwood statewide.  Part of the reason for this reforestation lies in the fact that there is a large and sustainable market for forest products, including the low-grade wood that is used for biomass. 

In addition to providing a renewable power source, the forest products market also contributes to the positive flow of forest CO2 and the forest system remains a net sink of CO2 from the atmosphere.  Furthermore, over 96% of electricity produced by pulp and paper mills (primarily through the use of biomass) is generated from highly efficient combined heat and power (CHP). The use of CHP provides energy efficiencies in the range of 50% to 80% compared to 30% for non-CHP systems. The sustainable use of forest products manufacturing residuals for energy provides enormous greenhouse gas benefits by avoiding the emission of about 181 million metric tons of carbon dioxide. The forest products industry has created a highly efficient, market-based system of managed forest use with significant carbon benefits including:

• Efficiently using biomass residuals through CHP to ensure forest biomass resources minimize total forest system GHG emissions;
• Reducing use of fossil fuels and reducing GHG emissions while simultaneously meeting society’s needs for forest products;
• Reducing potential GHG emissions that otherwise would result from residual disposal (e.g., methane from decomposition)
• Balancing forest supply and demand through market-based systems for biomass due to forest planting and re-growth, as evidenced by net increases in forest carbon stocks over most of the last 50 years; and
• Robustly recycling paper to reuse valuable biomass resources.

Virginia has long embraced an “all of the above” approach to energy generation, and we believe that it should continue to do so.  With that in mind, the 2018 Virginia Energy Plan would be incomplete without recognizing that biomass is an important part of the Commonwealth’s energy mix and forest products economy.  The final plan should reflect the importance of biomass energy.

Thank you.

Paul Russell Howe

Executive Director