There is a critical opportunity at hand for EPA to recognize the full benefits of biomass as a component of the nation’s wide array of energy resources. To help underscore that opportunity, the 25x’25 Alliance has joined some 80 biomass, agriculture, conservation and bioenergy groups in a letter to EPA Administrator Gina McCarthy requesting that any provisions associated with biomass the agency may develop as it completes its Tailoring Rule for biogenic carbon emissions be simple, practical and science-based, and to fully capture the long-term carbon benefits of biomass energy.
The rule adopted two years ago sets the requirements for certain stationary sources to obtain a Clean Air Act permit for their carbon emissions, though it “tailored” its scope by limiting those facilities required to obtain a permit to power plants, refineries and other large industrial plants, while exempting smaller sources like farms, restaurants, schools and other facilities.
However, the rule would for the first time regulate carbon emissions from bioenergy production the same as fossil fuel emissions. After concerns were raised by the biomass industry and its advocates, EPA delayed its implementation of the rule for biogenic carbon emissions for three years, until 2014, for further study.
But a recent ruling by the U.S. Court of Appeals for the District of Columbia Circuit vacated that delay, putting pressure on EPA to act now. The ruling has created significant uncertainty for biomass and forest products facilities that have begun operations, construction or major modifications since the agency first delayed implementing the rule two years ago. The uncertainty, in turn, could jeopardize the significant investments companies have made – and plan to make – to comply with other environmental regulations, improve energy efficiency and meet the growing global demand for pulp, paper-based packaging, wood products and energy.
By assuring any amendments to the rule fully recognize the long-term carbon benefits of biomass energy, EPA can sustain this critical renewable resource as a significant part of the “all-of-the-above” energy policy advocated by the Obama administration, as well as by many on both sides of the aisle on Capitol Hill.
There is a significant and growing body of scientific evidence concluding that carbon emissions from biomass do not introduce new carbon into the existing natural carbon cycle. It’s important to understand that in the United States, more wood is grown than harvested each year.
The Intergovernmental Panel on Climate Change recently compiled and analyzed 52 studies that had evaluated life-cycle greenhouse gas (GHG) emissions associated with various biomass power options, as well as other studies that characterized life-cycle GHG emissions for other renewable and non-renewable resources.
The panel’s findings show biopower life-cycle GHG emissions generally compare favorably with other renewable options, and offer significantly lower emissions than non-renewable options. In fact, biopower could offer lower GHG emissions than solar photovoltaic or geothermal energy, and lower than wind or hydro if the GHG emissions are included from avoiding the decomposition of biomass in landfills or forests.
The bottom line: Biogenic carbon is not adding to overall increases in GHG emissions and permits under the tailoring rule should not be required.
The 25x’25 Alliance and other biomass advocacy interests are ready to work with EPA in developing a final rule that secures the benefits of biomass energy as part of a diversified portfolio of renewable energy sources. A rule that underscores the value of biomass in meeting the nation’s GHG emissions challenges also will assure long-term forestland ownership and the sustainable retention of healthy forests.