"If wood is used for energy, it isn't waste."

WASHINGTON, DC - The National Alliance of Forest Owners (NAFO) submitted comments to the U.S. Environmental Protection Agency (EPA) on the Identification of Non-Hazardous Secondary Materials that Are Solid Waste proposed rule. The proposed rule identifies which non-hazardous materials traditionally used to generate renewable energy for combustion are considered solid waste under the Resource Conservation and Recovery Act (RCRA).
David P. Tenny, President and CEO of NAFO, said, "EPA made some positive steps in the rule to appropriately address the combustion of biomass for energy under RCRA. The law dictates that traditional fuel sources are not considered waste, and the forest products industry began using wood and wood residuals to generate electricity and heat decades before modern solid waste regulation. Ensuring appropriate treatment of biomass under the rule will help biomass make its full contribution to our nation's renewable energy goals."
RCRA regulates hazardous waste and differentiates combustion between traditional uses (i.e. biomass for energy) and incineration of waste materials - the latter of which is regulated under RCRA. NAFO is concerned that the proposed rule would unnecessarily narrow the materials indentified as non-wastes under RCRA to exclude biomass.
Tenny elaborated on the effects of this, "Experience shows that facilities will simply stop burning for energy recovery those materials that EPA labels ‘wastes,' since continuing to burn them would increase regulatory costs and create public relations challenges. There are certainly valid concerns about the need to contain emissions from the incineration of hazardous materials, but wood energy is clean, renewable, and a proven means of reducing carbon in the atmosphere."
NAFO's full comments are available on NAFO's website.