Accounting for Bioenergy Emissions, Benefits Must be Done Right

With the White House shining a very bright spotlight on its plans for addressing climate change – in particular, the long-awaited proposal to regulate carbon emissions from existing power plants under Clean Air Act ‑ it is important that the Obama administration give an equal amount of attention to a critical strategy available to stem greenhouse gases – bioenergy.

As noted in last week’s EPA proposal to cut back carbon emissions from power plants by 30 percent below 2005 levels by 2030, “burning biomass-derived fuels for energy recovery can yield climate benefits as compared to burning conventional fossil fuels”

However a big unresolved question is how the accounting framework used to calculate emissions from bioenergy will be structured. EPA is under federal court order to finalize regulations on biomass under the agency’s “Tailoring Rule.”

The rule adopted in 2011 sets the requirements for certain stationary sources to obtain a Clean Air Act permit for their carbon emissions, though it “tailored” the 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.

But as the rule was originally constructed, it would have meant for the first time carbon emissions from bioenergy production would be regulated the same as fossil fuel emissions. The biomass industry and its advocates were quick to cite the inequity inherent to evaluating biomass with fossil fuels and EPA delayed its implementation of the rule for biogenic carbon emissions for three years, until 2014, for further study.

While a ruling last year from the U.S. Court of Appeals for the District of Columbia would have vacated that delay, the appellate court actually stayed the implementation of its ruling. Still, EPA is under considerable pressure to act expeditiously, and with the scheduled expiration of the deferral for biomass set for next month, there is a real concern that bioenergy will fall into a default of being regulated the same as fossil fuels, such as coal.

Using sustainable biomass to produce energy mitigates greenhouse gas emissions by recycling atmospheric carbon – a result fundamentally different from using fossil resources, which continually add carbon to the atmosphere.

Efforts continue by the 25x’25 Alliance to bring stakeholders together and impress upon EPA that it must use the best available, current science as the agency finalizes a biogenic carbon accounting framework that reflects the true emission-reducing benefits of biomass. The fact that EPA expects states to use their framework as a resource in developing their own plans to comply with the proposed power-plant emissions rule makes it even more imperative that the framework be constructed properly.

EPA’s policy on biogenic carbon emissions must be timely, practical and cost effective, and must support rather than discourage the use of bioenergy as part of a diversified energy portfolio. An overly complex policy will increase cost and uncertainty, discourage the use of bioenergy (a low-margin energy source) in the marketplace and hasten the loss of private forests and other working lands, and as a result, reduce forest carbon stocks and carbon storage in the soil.

Among resources available to stakeholders calling on EPA to insure bioenergy is regulated fairly under the tailoring rule are comments submitted to the agency by the 25x’25 Steering Committee, with input from the Alliance’s Carbon Work Group, when the rule was first issued in 2010. The comments detail a “reasonable set” of 56 bioenergy accounting and policy issues that EPA and related government agencies must properly address in a coherent and comprehensive fashion in order for bioenergy to be fairly compared relative to fossil energy and other alternatives.

So, there are ample resources and expertise on hand for regulators who seek to better understand the major differences between fossil fuel and biomass emissions, and who want to construct a bioenergy carbon accounting framework that accurately assesses the contributions of biomass in government efforts to address rapidly occurring changes in our climate.

However, as important it is for policy makers to understand the value of bioenergy, any accounting framework that is developed must be subject to the federal intergovernmental review process. EPA may have the lead on the issue, but it is crucial that other agencies with major stakes in the development of biomass – including USDA, DOE and the Department of Defense – have input in advancing the framework. And any framework from EPA must be issued as a proposed rule – subject to public review, particularly by stakeholders ‑ rather than being adopted as a final guidance document.

Biomass energy can plan a major role in helping our nation transition to cleaner energy sources with significantly lower greenhouse gas emission. To reap these benefits however it is imperative that EPA get the biogenic carbon accounting framework right.

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