The Climate Report - Winter 2011

Although U.S. EPA recently issued guidance for regulators drafting Clean Air Act permits for greenhouse gas emitters, one issue that remains unclear is the status of biomass and biogenic emissions. EPA has announced that it plans to issue guidance in January 2011 on the environmental, energy, and economic benefits that may be attributed to the use of biomass, with further guidance to come in May 2011 on whether carbon dioxide emissions that result from the combustion of biomass must be controlled at new and modified stationary sources.

Biomass is biological material, most commonly plant matter such as wood chips, switchgrass, or corn, that is utilized to generate electricity or produce heat as a renewable energy source. EPA has stated that it does not have sufficient information to determine whether biomass emissions are carbon-neutral, and thus could be excluded from consideration in applying greenhouse gas permitting requirements. It solicited additional public comments, resulting in more than 7,000 submissions on this issue.

Proponents of biomass argue that such emissions should not be considered in applying the regulatory threshold, because burning plants simply returns to the atmosphere carbon dioxide that the plants removed as they grew, in contrast to burning fossil fuels, which results in emission of carbon that had been sequestered below ground for millennia. Opponents argue that the biomass cycle is not entirely carbon-neutral and does not adequately account for the effects of land-use changes.

EPA's guidance in the first part of 2011 should clarify two issues: (1) whether a stationary source's emissions from biomass combustion must be included in calculations to determine whether that source exceeds applicable permitting thresholds, and (2) whether "fuel-switching" from fossil fuels to biomass may be selected as the "best available control technology" in greenhouse gas emissions permits.

In the meantime, the U.S. Department of Agriculture is moving forward with plans to provide financial assistance under the Biomass Crop Assistance Program to farmers who grow commercial biomass crops, such as switchgrass, sorghum, hybrid poplars, and willows. Under the final rule, published October 27, 2010, 50 million acres of existing pasture land and traditional cropland would be converted to biomass energy production. The USDA believes that this broad program is necessary to meet the federal renewable fuel standard, which requires production of 36 billion gallons of renewable fuel, including fuel from biomass, by 2022.

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