EPA’s Biogenic Carbon Framework: A New Chapter For Biomass

Bob Cleaves offers his reaction to the Environmental Protection Agency's November release of the Revised Framework for Assessing Biogenic CO2 Emissions from Station Sources.
By Bob Cleaves | December 26, 2014

When the Clean Power Plan, the EPA’s nationwide carbon reduction plan that sets specific emissions targets for each state, was released June 18, the EPA and the Agency’s Science Advisory Board had not yet completed their work on the carbon accounting of biogenic emissions. Important questions regarding how the EPA should model biogenic emissions and thus how biomass power could play a role in reducing overall carbon emissions were left unresolved.

As I have said in past columns in Biomass Magazine, biomass energy plays an important role in the mix of energy sources helping to reduce U.S. GHG emissions. The White House, the Environmental Protection Agency’s Science Advisory Board, and the international scientific community have all recognized that sustainable biomass can be an important source of low-carbon energy, particularly waste biomass and residues from sustainable forestry management and forest products manufacturing.

These materials provide consistent, baseload, renewable sources of energy and should be given a clear pathway for utilization by the EPA in any rulemaking regarding biogenic emissions. Biomass energy is recognized in nearly every state that has a Renewable Portfolio Standard. Failure to adequately credit the carbon mitigation attributes of low-carbon sustainable biomass in the final rule could result in state compliance plans that exclude this clean energy technology, the potential closure of biomass facilities, and a lost opportunity for greater GHG reductions. But, due to an onslaught of litigation from groups opposed to biomass, we have been left on the edge of our seats for the better part of four years to see how the EPA would decide to count biogenic carbon emissions.

Luckily, we no longer have to wonder. Nov. 19, the Agency released the Revised Framework for Assessing Biogenic CO2 Emissions from Stationary Sources and its accompanying memorandum to states from acting assistant administrator McCabe. Together, the Framework and the EPA’s implementation of it support a clear, science-based approach that provides regulatory certainty while deferring important policy implementation to the states.

Dec. 1, BPA filed comments with the EPA on the CPP, which can be found on our website. While the big picture—that the EPA recognizes the value of biomass as a renewable energy source that should contribute to the nationwide reduction of carbon emissions—is very positive, there are still questions that we need answered.

We welcome the EPA’s determination that waste-derived materials, biogas and forest-derived industrial by-products 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.” We have asked the EPA to clarify in the final plan that nonforestry cellulosic materials—like urban wood, wood-derived construction and demolition debris, and railroad ties—be specifically included in the definition of “waste-derived feedstocks” since these organic materials do not cause land use changes and do not deplete carbon stocks.

Also, regarding the EPA’s decision to include in the plan “sustainably derived” forest-derived feedstocks, we urge the EPA to recognize that for decades, states have managed their forests using sustainable land management practices. Existing state laws promote and protect healthy forests, and the plan should recognize that the EPA does not have the expertise or resources to set or enforce sustainability standards.

Finally, we encourage the EPA to clearly state that biomass power plants that use feedstocks covered by the McCabe Memorandum are exempt from regulation under the Clean Power Plan. To the contrary, biomass power from renewable and sustainable feedstocks should be encouraged as a compliance tool under Section 111(d).

All in all, the news from the EPA is a good sign for the biomass industry. After waiting several years for the revised framework, this document, along with the memo to states encouraging the counting of biomass in the Clean Power Plan, are a great way to kick off 2015, and a new, more stable, chapter for biomass.

Author: Bob Cleaves
President and CEO, Biomass Power Association