SAB responds to EPA's biogenic emissions framework

The U.S. EPA’s Science Advisory Board (SAB) has issued a draft report response to the EPA’s Accounting Framework for Biogenic CO₂ Emissions from Stationary Sources. The framework was first issued by the EPA in September.

The SAB draft report addressed many large questions relating to the framework, and also addressed the role of the Biogenic Accounting Factor (BAF), a system developed by the EPA to calculate biogenic emissions. The SAB also addressed the carbon neutrality of biomass, declaring it cannot be considered carbon neutral in all cases, but instead needs to be reviewed on an independent situation-by-situation basis that takes into account the feedstock’s production and consumption cycle.

The SAB disagrees with EPA’s assumption that biomass produced and consumed in different regions may have different carbon emission values, the report states. The report also proposed a feedstock measurement system that considers longer carbon sequestration periods for biomass that would more accurately reflect the sequestration cycle that occurs over a longer period of time for certain biomass feedstock. To solve the deficiencies associated with the BAF, the SAB suggested three possible changes to the framework: develop a BAF for individual feedstocks; create certification systems for feedstock users and providers that include best practice certifications; and use offset systems that would allow stationary energy producers to contract with landowners to offset their emissions via forest protection and regrowth.

Although the draft report is by no means conclusive or finished, according to Angela Nugent, designated federal officer for the EPA, it is part of a process that will allow the EPA administrator to make a decision on biogenic emissions from stationary sources.  EPA’s September framework on biogenic emissions stems from the Greenhouse Gas Tailoring Rule first issued by the EPA in 2010. The rule did not initially exclude biogenic emissions from compliance. In July 2011, the EPA delayed the permitting requirements for biogenic emissions from stationary sources for three years, in order to further research their impact on the environment.

The SAB includes experts in the forestry, agriculture, greenhouse gas measurement, land use economics, ecology, climate change and engineering sectors. The panel was tasked to review the overall approach used by the EPA, as well the accounting practices, and suggest improvements to the original framework accounting model.

While the draft report is still a work in progress, the SAB will meet again in January and then again in March to discuss its report before presenting a final decision on the Framework for Biogenic CO₂ Emissions from Stationary Sources to the EPA administrator. A draft of the report can be viewed here.