This month, black liquor was back in the news, and chances are you’ll be hearing a lot more about it through the rest of 2013. Black liquor is a byproduct from the kraft pulping process, which turns pulpwood into paper pulp by separating the cellulose fibres. The black liquor sludge is recovered and burned for fuel to provide the majority of energy for the forest and paper industry.

First, readers may recall the tragic events of late 2011, when a massive release of black liquor sludge poured into a river in southern Louisiana for several days before being stopped. The result was a river starved of oxygen, full of floating dead fish and threatening the health and livelihoods of people along the river. The mill owner responsible is now paying the price as reported this month in the Times-Picayune,

“Temple Inland, a subsidiary of International Paper, pleaded guilty in federal court [February 6th] to polluting the Pearl River in August 2011 with illegal discharges from its Bogalusa paper manufacturing plant, and killing more than 500,000 fish, including more than 1,000 in the Bogue Chitto National Wildlife Refuge. The company could be fined up to $200,000 for violating the Clean Water Act, and up to $10,000 for each “taking” of wildlife in the refuge.”

While the Clean Water Act was violated by the release of black liquor into the Pearl River in this case, 2013 will bring scrutiny to the air emissions of black liquor combustion. The stage is set for two historic decisions for the U.S. Environmental Protection Agency (EPA) relevant to CO2 pollution from black liquor’s use as a fuel, that could help us move towards more efficiency and reduced greenhouse gas emissions from an industry that is the third largest energy user (1) among manufacturers in the United States.

The Supreme Court has declared that the Clean Air Act compels the EPA to regulate CO2 as a pollutant. Therefore, two separate reviews this year by EPA that encompass kraft, or chemical, pulp mill emissions must for the first time include thorough consideration and accurate accounting of CO2 emitted, both fossil and “biogenic.”

The EPA defines “biogenic CO2” as CO2 emissions directly resulting from the combustion, decomposition, or processing of biologically based materials other than fossil fuels, peat, and mineral sources of carbon through combustion, digestion, fermentation, or decomposition processes. The forest and paper industry is the largest consumer of bioenergy in the United States, including its burning of black liquor, and is collectively the largest emitter of biogenic CO2 pollution. For example, visit the EPA’s FLIGHT webpage (Facility Level Information on Greenhouse gases Tool). Click on any pulp mill, and note the volume of biogenic emissions that are currently recorded, but not counted.

The EPA is deep into a three-year scientific review and regulatory process scheduled to be complete in January 2014 which will develop carbon accounting methods and greenhouse gas emissions thresholds for large stationary sources of biogenic CO2. Rules have already been issued for CO2 from fossil fuel based emissions under Prevention of Significant Deterioration (PSD) and Title V Operating Permit Programs of the Clean Air Act.

But the unique dynamics and emerging science required a three year deferral for biogenic Co2 emission. An independent, expert science panel commissioned by EPA to review its draft accounting methodology recently delivered its final report. The report reinforced the conservation community’s position that biogenic emissions can not be deemed carbon-neutral, a priori, or automatically. The EPA’s draft  accounting framework proposed that if forest stocks are increasing regionally, then new large stationary biogenic sources in that region do not need a permit. However, the science panel rejected this approach as too simplified and unscientific, and too detached from EPA’s obligation to regulate emissions at each smokestack.

Secondly, the EPA has been compelled by the courts to review its air emissions regulations for kraft pulp mills following a lawsuit by Environmental Paper Network member organisations Greenpeace USA, Port Townsend Airwatchers, and the Center for Biological Diversity. Section 111 of the Clean Air Act, requires EPA to develop regulations for categories of sources which cause or significantly contribute to air pollution which may endanger public health or welfare. The EPA has not reviewed kraft pulp mill emission-control standards, called “New Source Performance Standards,” for more than 25 years, though it is required to do so every eight years or less.

Recognizing the significance of these decisions, The American Forest & Paper Association has identified its top policy priorities for 2013. Among the top items listed are working with the US Environmental Protection Agency to develop “practical and sustainable air regulations” and secondly, to “allow” biomass to be recognized as a carbon-neutral fuel source in greenhouse gas regulations.  On these specific issues, the organisations in the Environmental Paper Network have a different perspective and different goals than the AF&PA.

Few would argue that we should not recover black liquor and use it in this manner. With our current technology and reliance on virgin tree fibre it is part of relatively efficient manufacturing process and a preferable destination compared to the landfill. When its use displaces fossil fuels for energy there can be a net benefit. But cutting a forest and converting it to a short-lived product and CO2 emissions is absolutely a choice that has an impact and must be measured.

Everyone should agree that we must assign scientifically accurate accounting to atmospheric CO2 to the facility that emits it in order to design accurate and legal regulations that provide certainty to producers and a level playing field.  Right now, corporations and governments are creating systems to institutionalize sustainability decisions and measure the carbon footprint of different choices such as virgin tree fibre paper vs. recycled paper. We can’t artificially discount the impact of one process without skewing the comparisons with another choice.

The Environmental Paper Network and its member organisations have been at the forefront of the advocacy for incorporating the latest science on the climate implications of using bioenergy extracted from forest sources. Therefore we will continue to directly participate and to mobilize climate experts and conservation advocates to engage in these two key regulatory processes. Our goals are to ensure that the voice of impacted communities and our children’s future are represented in this process. It is critical that the EPA has a complete understanding of the science and the implications of their decisions. Too much is at stake to simply “allow” this fuel source to be classified as automatically carbon-neutral when there is strong evidence that it is not.

If you or your organisation have any information about local air pollution matters associated with pulp and paper mills or would like join in our coordinated efforts, please contact us via info (at) with “AIR POLLUTION” in the subject line.


1 – EIA, 2006 Manufacturing Energy Consumption Survey, available at