EPA seeking information on greenhouse gas accounting for bioenergy

The U.S. Environmental Protection Agency (EPA) has issued a Request for Information on Greenhouse Gas Emissions Associated with Bioenergy and Other Biogenic Sources(Federal Register July 15, 2010, p. 41173). EPA is trying to determine what approach to use in regulating greenhouse gas (GHG) emissions from biomass combustion and other biogenic sources under the Clean Air Act.

In its final “Tailoring Rule” (Federal Register June 3, 2010, p. 31591), EPA decided to include GHG emissions from biomass combustion sources in its PSD and Title V permitting programs, despite the fact that CO2 emissions from biomass combustion are not included in the reporting threshold of EPA’s Greenhouse Gas Reporting Rule and are assigned an emission factor of zero in EPA’s national greenhouse gas inventory and the Department of Energy’s GHG voluntary reporting program.

In the preamble to the “Tailoring Rule,” EPA indicated that further study would be given to this decision. EPA was not specific as to what alternatives would be considered, nor did the agency commit to a schedule for making any decisions. EPA did state they would seek comment on how to address biogenic carbon under PSD and Title V, and on the legal and policy issues raised by various implementation options.

In its Request for Information, EPA expressed interest in obtaining technical comments and data related to accounting GHG emissions from bioenergy and other biogenic sources with respect to how these emissions should be treated 1) specifically in the PSD and Title V permitting programs; and 2) in general, without regard to specific rulemakings. Some specific questions posed by EPA that are of interest to the forest products industry include:

  • How should the benefits and impacts of using biomass fuels be considered in BACT (Best Available Control Technology) determinations for PSD permits?
  • What alternative accounting approaches, other than assuming carbon neutrality of CO2 emissions from biomass combustion or treating CO2 emissions in the same way as fossil fuel emissions are treated, are available?
  • What indicators could be used to identify biomass fuels that are “renewable” or “sustainable”?
  • How should EPA deal with non-combustion biogenic GHG emissions, such as those from landfills and wastewater treatment systems?
  • Should the concept of “carbon neutrality” for biogenic CO2emissions from combustion sources be applied to individual facility emissions or should it remain applicable only at a nationwide scale?

NCASI will be preparing technical information in response to this EPA request. The material may be submitted directly to EPA, or it may be incorporated into comments being prepared by AF&PA and the National Association of Forest Owners.

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