Industry provides input to SAB Biogenic Carbon Emissions Panel

By Erin Voegele | April 01, 2015

In late March, the U.S. EPA’s Science Advisory Board Biogenic Carbon Emissions Panel held a public face-to-face meeting to review the agency’s Framework for Assessing Biogenic CO2 Emissions from Stationary Sources. A public teleconference of the panel is scheduled for May.  

The U.S. EPA released the second draft of its biogenic emissions framework in November. At that time, the EPA indicated the draft framework would undergo additional review and published a memo outlining how the updated framework would impact the Clean Power Plan and Prevention of Significant Deterioration Program.

On March 25-26, the SAB Biogenic Carbon Emissions Panel held a face-to-face meeting in Washington, D.C., to review the updated framework. A meeting presentation published by the EPA explains that the EPA released the first draft of its biogenic carbon emissions framework in 2011. In early 2012, the SAB issued a draft report response. The EPA’s meeting presentation outlines the 2012 peer review findings and provides an overview of the revised framework that was released in November. The agency also describes specific areas in which it is seeking additional panel recommendations.  

As part of the meeting, members of the public were able to submit comments to the SAB regarding the biogenic emissions framework. Robert Cleaves, president of the Biomass Power Association, was among those to submit comments. In his testimony, Cleaves described the primary feedstocks used in bioenergy production, noting that the industry primarily uses waste feedstocks.

“Energy has and always will be the least attractive market for biomass,” Cleaves wrote. “So long as power prices remain low relative to the value of sawlogs, pulpwood or, if necessary, the conversion of forest land for development, the economics of our industry limit our fuels to what others might call ‘wastes.’ Though derived from various sources, almost all of the fuels used by our industry share certain fundamental characteristics: they (1) are not grown and harvested specifically for energy; (2) do not cause direct or indirect landscape changes; (3) if not used for energy would likely decompose, be landfilled, be openly burned, or exacerbate fire and disease risks in the nation’s overgrown forests.”

In his comments, Cleaves described the current state of the U.S. biopower industry and noted that regardless of region, all U.S. biomass plants are unable to complete with higher value uses for biomass, such as sawlogs and merchantable pulp. “As a result, even if EPA were to conclude that all biomass is ‘carbon neutral,’ the fear that biomass electricity would somehow undertake major harvests and compete with the value of pulp and sawlogs is fantasy. Use of fuel is not a function of carbon accounting; it’s a function of price,” he said.

Becuase price defines the industry’s feedsock options, Cleaves aid the BPA urges the SAB and EPA to focus on a well-defined subset of biomass—the low value feedstock currently in use—when finalizing the framework. “First, use of these fuels does not affect net growth on the production landscape. Second, as documented by the Green Power Institute, conversion for power avoids emissions that would otherwise occur, such as from decomposition or forest fires. Third, use of these fuels does not result in land use changes or management,” he continued.

The Biotechnology Industry Organization also submitted comments. Referencing the memo issued by Acting Administrator Janet McCabe in November that outlined the EPA’s current thinking pertaining to biogenic CO2 emissions in the context of the CPP and PSD program, BIO said it believes all renewable biomass is sustainable and should be exempt from carbon accounting. “We are encouraged by Administrator McCabe’s view that many states can and should rely on biomass to meet carbon reduction targets under the Power Plant Rule,” wrote BIO in its testimony. “BIO and its members view these statements as positive signals of EPA’s intent to recognize the carbon benefits of biomass to the overall reduction of GHGs. This recognition and message should be made even more explicit in the final version of the Framework.”

In its comments, Covanta said it supports the inclusion in the revised framework of an alternative fate approach for waste-derived feedstocks and that both carbon dioxide and methane are explicitly included for forest, agricultural, and waste sector-derived feedstocks. DuPont Industrial Biosciences addressed its cellulosic ethanol plant in Nevada, Iowa, which takes in corn stover as feedstock. The company pointed out that corn and other agricultural feedstocks are annual crops, which means the amount harvested and any burned is balanced by the amount that grows during the year. DuPont also noted that corn stover left on the field degrades, resulting in methane emission and that using that since bioenergy is generated locally, it results in minimal transportation emissions. The National Alliance of Forest Owners, and the Biogenic CO2 Coalition are also among the organizations that submitted comments to the panel. Copies of the testimony and additional meeting information can be downloaded from the EPA SAB website.

The SAB Biogenic Carbon Emissions Panel also plans to hold a teleconference on May 29 from 1:00-4:00 p.m. Information on how to request time to make an oral presentation during that event or submit written comments prior to the teleconference can be found on the Federal Register website.