Environmental Protection Agency
Air and Radiation Docket and Information Center
Mailcode 2822T
1200 Pennsylvania Ave., NW
Washington, DC 20460

RE: Docket EPA-HQ-OAR-2005-0161

To Whom It May Concern:

The National Association of State Foresters (NASF) appreciates the opportunity to provide comments in response to EPA's Proposed Rule on the Regulation of Fuels and Fuel Additives: Changes to Renewable Fuel Standard (RFS) Program. State Foresters have the primary responsibility for the protection and management of 2/3rds of the nation's forests (i.e. those outside federal ownership) and believe a RFS holds enormous potential for improving the health of the nation's forests while also meeting national goals for renewable fuels production.

Congress and the president have expressed their support for addressing energy security by passing the Energy Independence and Security Act of 2007 (EISA) which installed a RFS calling for 36 billion gallons of renewable fuel to be sold or dispensed by calendar year 2022. By passing the EISA, both the president and Congress have included a key role for forests as source of renewable biomass.

President Obama's guiding principles on securing the nation's energy future call for investments in clean energy sources that reduce our dependences on unpredictable foreign oil markets. In order to achieve energy independence, President Obama made it clear in a memo to the Secretary of Agriculture, Secretary of Energy and the EPA Administrator that biomass will play a key role in providing a domestic source of clean renewable fuels while also energizing the nation's economy. In addition to avoiding greenhouse gas emissions associated with fossil fuel production, utilizing forest biomass for energy production mitigates emissions often associated with wildfires, slash pile burning and decomposition in landfills.

NASF strongly believes that emerging markets for renewable fuels and renewable energy hold great promise for keeping our nation's forests-and their climate change mitigation potential-intact . New income streams from biomass markets will help families and individuals cover the cost of owning their forests and resist conversion to non-forest uses. Further, the RFS can help generate markets for biomass which will help drive down the cost of forest health and fuels reduction treatment across all the nation's forests improving their ability to sequester carbon while simultaneously providing a renewable energy crop.

Accomplishing the nation's renewable and secure energy future while accomplishing other environmental benefits will hinge on the ability of EPA to broadly interpret the renewable biomass definition found in EISA. While NASF holds that the EISA overly restricts the ability of the nation's forests to contribute biomass, we believe a narrow interpretation from EPA will further inhibit the ability to meet the RFS. State foresters are leaders in promoting healthy, sustainable trees and forests across the nation and offer our detailed comments as EPA promulgates a final rule that recognizes the critical role woody-biomass will play in achieving climate and energy goals set forth in EISA.

Sincerely,

Steven W. Koehn

Click on .pdf below for comments from NASF on the RFS