EPA’s Biogenic Carbon Rules Positive, but Not Out of the Woods Yet

On November 19, the EPA released a long awaited Framework for Assessing Biogenic CO2 Emissions from Stationary Sources.  EPA promised to further clarify emissions from the biomass power sector, referred to as biogenic carbon, prior to the close of public comments on the Clean Power Plan on December 1.  Biomass power refers to the burning of wood and cellulosic wastes (such as agricultural or timber waste) for energy. While this week’s release of the Framework provides further clarification, and redemption, of utilizing biomass wastes for energy, no specific carbon emissions number has been assigned to woody fuels in the new framework.  Going forward, quantifying carbon emissions from woody fuels is important because individual states will need to assess how their wood-based energy resources may or may not qualify under the Clean Power Plan.

The Framework is a follow-up to the much maligned 2011 Draft Accounting Framework, which drew criticism from individuals and industries on both sides of the issue, as well as EPA’s independent Scientific Advisory Board (SAB), which commented “the solutions offered [by EPA] in many cases, particularly those related to the use of harvested wood for bioenergy, lack transparency or a scientific justification.”  EESI maintains, as do many forestry groups, scientists, and forestry products industries, that there is a fundamental difference in carbon emissions from burning fossil fuels, versus the burning of biomass that is sustainably harvested and re-grown, and thus able to sequester additional carbon.  Additionally, providing an economic incentive to maintain farm and forested lands, as bioenergy and biofuels do, can also help to preserve forests and farms in the face of rampant exurban development.  In the new framework, EPA has added additional information on the very complicated nature of carbon accounting in landscapes. The EPA’s new Framework will now go back to the Scientific Advisory Board for peer review. 

But for now, EPA’s Framework further makes the case for biomass energy as a part of sustainable forestry management.  In the Memorandum from Janet McCabe, Acting Assistant Administrator of Air and Radiation, to Regional Air Division Directors, EPA states “the generation of sustainably sourced bioenergy products can be an integral part of regimes that promote conservation and sustainable forest management.”  EPA makes a case for utilizing ‘waste-derived feedstocks’ as well as ’forest-derived industrial by-products’ to be utilized for energy, stating that they “are likely to have minimal or no net atmospheric contributions of biogenic CO2 emissions, or even reduce such impacts, when compared with an alternate fate of disposal.”  

For the Clean Power Plan, EPA “expects that states’ reliance specifically on sustainably-derived agricultural-and forest-derived feedstocks may also be an approvable element of their compliance plans.”   Importantly, EPA recognizes that “every state has different energy systems and available fuel mixes.”   Utilizing cellulosic wastes for energy is already an important part of many states’ Renewable Portfolio Standards (RPS), with states utilizing pellet fuels sourced from timber waste, such as sawdust, chips and scraps, as well as agricultural wastes. While cellulosic ethanol is poised to flourish in the Corn Belt, not every state has the infrastructure for collection or volumes of agricultural waste necessary for an ethanol plant.  Therefore, in many places, a storable, transportable solid fuel makes perfect sense.

The question remains how, exactly, biogenic carbon will be treated by the forthcoming Tailoring Rule. It is now up to SAB to review EPA’s suggested carbon accounting framework or to require further refinement from the agency. The rules could become very complicated, especially because ‘sustainability’ is a broad concept, and defining it clearly with regard to biogenic carbon is critically important. EPA expects SAB to solicit public comments on the carbon accounting work provided in the second Framework.

For Additional Information See: 

EPA Biogenic Carbon Memo

EPA Request for Review by SAB

EPA “Gets It” if They Focus on the Carbon, National Alliance of Forestry Owners