It’s In the Plan: EPA Offers Clues on Woody Biomass Utilization

Over the past several months, biomass stakeholders have expressed frustration at the administration’s failure to label the use of biomass feedstocks as carbon neutral.  The pellet industry and biomass advocates argue, that so long as forest stocks are stable or increasing, the administration should allow forestry residues to be labelled as carbon neutral under the Clean Power Plan (CPP).  Doing so would certainly simplify the inclusion of forestry residues as renewable electricity generation in individual state compliance plans.
 
Yet, it doesn’t appear that the pellet industry will get what it wants. The CPP was finalized in August, but the Scientific Advisory Board (SAB), the group tasked by EPA to understand the greenhouse gas lifecycle of a myriad of biomass feedstocks is still ongoing. Efforts by Congress to have biomass labeled as carbon neutral by the administration have been rebuffed. 
 
At the same time, states must either finalize their individual compliance plans by September of 2016, or file for a two year extension at that point.  It’s becoming clear that holding out hope for a label of carbon neutrality is risky and ill-advised. Doing so would mean missing out on the role industry can play in renewable generation for the foreseeable future, as the Clean Power Plan will dominate domestic power production until it expires in 2030.
 
Just as states have been left to their own devices in the CPP, states will be on the hook to figure out how to exactly include biomass. But at the same time, the agency also offers abundant clues as to how the agency will treat biomass. As states work with stakeholders to prepare compliance plans, a careful read of the Clean Power Plan and other EPA documents on biomass is warranted.
 
In the CPP, EPA states that “waste-derived and industrial byproduct biomass feedstocks would likely be approvable as qualified biomass” so long as appropriate monitoring and verification of feedstock sourcing is in place.  In the CPP, EPA also calls out several states’ forestry management plans as being examples.  By including these examples, EPA is asking for not only monitoring of lifecycle emissions for biomass feedstocks, but proof of good forestry practices. This makes sense, as managing the forests must go beyond simple carbon verification but also ensure long-term forest health.
 
There are several areas in which the industry and stakeholders can interact positively with the administration.  While the CPP is finalized, EPA is still accepting comment on the proposed Federal Implementation Plan (FIP) until January 21.  This is the plan that will be imposed on states that do not write their own plans.  Currently, biomass is not included in the FIP, but it could be helpful for stakeholders to provide comments urging the inclusion of biomass and a list of qualified feedstocks to be included in the FIP.  To provide comments, visit the proposed rule at Regulations.gov and click ‘comment now’.
 
In the energy sector, the FIP is viewed as the “stick” so that states are compelled to write their own compliance plans. But, if biomass is thoughtfully included in the FIP, it could also provide a helpful boost to states that need assurance on what biomass feedstocks may qualify now and in the future.
 
In a recent blog post by EPA Air and Radiation Administrator Janet McCabe, it was revealed that the agency will be hosting at least one stakeholder meeting on biomass in the New Year. According to McCabe, the workshop will be a platform for “stakeholders to share their successes, experiences and approaches to deploying biomass in ways that have been, and can be, carbon beneficial.”  Tuning into these meetings will be key in deciphering what will and won’t be acceptable as far as tracking, verifying and monitoring industry.
 

McCabe writes that “biomass derived from land that is managed under programs that ensure the long-term maintenance of healthy forests can serve as an integral part of a broader forestry-based climate strategy, so the CPP expressly includes bioenergy as an option for states and utilities in CPP compliance.”  She goes on to state that EPA expects to certify biomass in many states, and that “We look forward to reviewing plans that incorporate well-developed forestry and other land management programs producing biomass that can qualify under the guidelines laid out in the CPP.”

EPA is opening the door to the biomass industry. Certainly, fitting biomass into the CPP will require some creativity on the part of industry to make sure all the boxes are checked as far as compliance.  It will require not only carbon certification but robust state forestry practices. Just as each state’s energy mix is different, each state’s biomass resources are unique, and will require an individualized approach to harmonize sustainable forestry and biomass utilization.
 
One thing is abundantly clear -- early conversations between state energy offices, industry players, air regulators and EPA could go a long way towards making a strong case for inclusion of a particular biomass feedstock or pathway.  As EPA states, forest health initiatives and biomass can be an integral part of the Clean Power Plan, but will require creativity to fully realize.
 

For more information see: 

The Role of Biomass in Achieving Clean Power Plan Goals – A 2016 Workshop to Foster a Constructive Discussion, EPA