As The Biomass Turns…Greenhouse Gases from Biomass and Biogenic Sources
Posted: November 21st, 2012Author: All4 Staff
The regulatory community has become (for the most part) accustomed to the permitting requirements for greenhouse gases (GHGs). It has become second nature to include them in emission inventories; as part of Prevention of Significant Deterioration (PSD) applicability reviews; and Title V applications. To date, industry has been able to exempt emissions of GHGs from biomass and biogenic sources from permitting based on a U.S. EPA deferral. This deferral is scheduled to expire in 2014 and the obvious question is “what happens then?” Well, take note of this: last month, as reported in the October 11, 2012 Clean Air Report, the U.S. EPA’s Science Advisory Board (SAB) recently submitted its final report suggesting ways to improve U.S. EPA’s draft biomass accounting framework (BAF) for use in evaluating emissions of GHGs from biomass. The SAB’s report was essentially a full approval of its July 2012 report (with minor changes), and included an opinion from one member urging complete exemption for biomass GHGs from air permitting requirements (as an appendix to the final report). The U.S. EPA’s BAF has been railed for its complexity, uncertainties, data deficiencies, and implementation challenges. The SAB report does not include a recommendation to sustain or eliminate the permitting exemption in 2014 and beyond.
U.S. EPA can consider the SAB report and make revisions to the BAF, or it can move forward with a rule to formalize the BAF and eliminate the permitting exemption. As reported in the Clean Air Report, the temporary exemption still faces legal challenges that are awaiting oral arguments. The National Alliance of Forest Owners (NAFO), which was the group that successfully petitioned the GHG biomass permitting deferral, proposes that U.S. EPA reject the SAB report since it “confuses rather than clarifies the path forward,” and supports the continued exclusion of biomass emissions in a GHG regulatory program “so long as forest carbon stocks in the U.S. are stable or increasing.”
Dissention between U.S. EPA and industry, between U.S. EPA and its own SAB, and retention of the political status-quo makes this one story worth watching.