The Environmental Protection Agency (EPA) recently created rules that require monitoring and regulating of CO2 and other greenhouse gas emissions in Clean Air Act permits for large stationary sources of emissions. The “tailoring rule” establishes the agency’s framework for evaluating and limiting these emissions.

The “tailoring rule” is being challenged by industry interests and several members of Congress in the D.C. Circuit Court of Appeals (Southeastern Legal Foundation, et al. v. US EPA), arguing that burning biomass for energy is “carbon-neutral” and requires no evaluation.  On July 6, Wild Virginia, represented by the Southern Environmental Law Center, along with Georgia ForestWatch, the Conservation Law Foundation and the Natural Resources Council of Maine, “intervened” in support of the EPA regulations, by filing declarations with the court explaining how overturning this rule could significantly threaten Virginia’s forests.  The press release is viewable here.

The EPA decision to analyze emissions from burning biomass as it regulates greenhouse gases from large power plants and other large industrial facilities is an extremely important decision.  The rule insightfully includes a commitment to continue a scientific evaluation of the true carbon impact of all methods of creating energy, including the many forms of biomass energy.

Large-scale biomass incineration poses a double threat to Virginia’s forests. Already the George Washington National Forest is considering an increase in the yearly acreage and amount of logging, which would allow for potential increases in demand for “whole trees.” But if biomass incineration also increases the rate of increase in CO2 emissions, given climate change already in evidence, it could have negative domino-type effects for the forest plants, animals, air and water quality. The EPA rule will let the public know upfront how proposed incinerators will affect Virginia’s air, water, climate and forests.

Wild Virginia’s President, Nathan Van Hooser, and Wild Virginia member Peyton Coyner, who is a Nelson County resident, each filed affidavits in the motion to intervene. Peyton notes that “I’ve hiked and camped in the national forests of Virginia for over a half century, and I’ve seen the changes - fewer brook trout, hazier views, more invasive plants and insects - which I think are at least partly due to a warming climate. But if we move too hastily on using biomass as a major source of energy, we might end up destroying our forests altogether, so it’s important that when it’s done, it’s done right.”

The May 17, 2010 letter to Harry Reid and Nancy Pelosi supports the EPA action. “Replacement of fossil fuels with bioenergy does not directly stop carbon dioxide emissions from tailpipes or smokestacks. Although fossil fuel emissions are reduced or eliminated, the combustion of biomass replaces fossil emissions with its own emissions (which may even be higher per unit of energy because of the lower energy to carbon ratio of biomass)… clearing or cutting forests for energy, either to burn trees directly in power plants or to replace forests with bioenergy crops, has the net effect of releasing otherwise sequestered carbon into the atmosphere, just like the extraction and burning of fossil fuels. That creates a carbon debt, may reduce ongoing carbon uptake by the forest, and as a result may increase net greenhouse gas emissions for an extended time period and thereby undercut greenhouse gas reductions needed over the next several decades.”

What happens next? In the absence of a comprehensive energy bill that “clears the air,” the DC Circuit Court, or eventually the Supreme Court, may have to be the ones to “do the right thing” when it comes to the EPA’s effort to accurately assess CO2 emissions.

In December 2008, Wild Virginia completed a study of the drinking water resources of the George Washington National Forest (GWNF). The GWNF is a very important regional and local source of drinking water. Twenty-two localities in western Virginia obtain some or all of their drinking water from the surface waters of the GWNF. Appropriate management of the GWNF is essential, as local drinking watersheds comprise approximately 44% of the GWNF lands within Virginia.

View maps and read more about the findings in The State of Our Water. Click to view the Executive Summary (2mb) or the Full Report (5mb). View the Press Release announcing the study and report by clicking here.

Based on information in the report, and through outreach on our part, the Shenandoah Valley Network, and other partners, 40 organizations have adopted resolutions calling on the U.S. Forest Service to improve management of drinking water resources in the GWNF.  Sixteen of the organizations are local governments, such as city councils and county boards of supervisors.  Many other organizations are public entities as well.  Click here to see the list of organizations, and to be able to view some of the resolutions.  All the resolutions have been submitted to the U.S. Forest Service as comments on the Forest Plan for the GWNF.

Water quality in the GWNF is a concern, as fifty streams or rivers and six reservoirs in the national forest were designated as “impaired” in a 2006 statewide water quality assessment by the Virginia Department of Environmental Quality. Many of these impaired waters are found in local drinking watersheds. (None of the waters were found to be impaired for use as a “public water supply” though.)

The State of Our Water recommends several steps the Forest Service can take to improve the long-term management and protection of drinking water resources in the GWNF. Some very basic recommendations include formally identifying the drinking watersheds within the GWNF, develop management plans and objectives specifically for the drinking watersheds, and work closely with local communities in the planning and management activities.

The current Forest Plan for the GWNF was completed in 1993. Unfortunately, the Plan does very little to address drinking water quality. In fact, The State of Our Water found almost no difference in management of GWNF lands when comparing areas within the drinking watersheds to areas outside the drinking watersheds.

With the Forest Plan currently under revision, now is the ideal time to assess ways to enhance management of drinking water and all other resources of the GWNF. The Forest Service has been seeking public comment on the Forest Plan for many months, and will continue to do so in the early part of 2009. Please become engaged by communicating to the Forest Service how you believe the GWNF should be managed, and what the management priorities should be.

Comments may be made via letters, emails, phone calls, and faxes. They should be sent to the George Washington-Jefferson National Forest Headquarters in Roanoke, Virginia. Contact information is:

Mailing address:

Maureen Hyzer, Forest Supervisor

George Washington National Forest

5162 Valleypointe Parkway

Roanoke , VA 24019-3050

Email address:

Comments-southern-georgewashington-jefferson@fs.fed.us

(Please write “Comment on George Washington Plan Revision” in the subject line.)

Phone numbers:

(888) 265-0019

(540) 265-5100

Fax numbers:

(540) 265-5145

(540) 265-5109

For many years, Wild Virginia has worked to protect the wood turtle at the southern end of its range here in Virginia and West Virginia. With much of its habitat on private lands having been degraded, fragmented, and lost altogether through the years, public lands offer the best opportunity to protect and maintain a viable population of these vulnerable animals for the long term.

Creating a Special Biological Area in the George Washington National Forest, with an objective of effectively managing and protecting a wood turtle population, is critical for the future of the wood turtle in Virginia. Please write to the U.S. Forest Service and urge them to create a Special Biological Area for the wood turtle. With the Forest Plan for the GWNF currently under revision, please act now to make your ideas a part of the planning process. Click here to get contact information and read more about Forest Plannng.