A letter on the neutrality of carbon was sent to germane federal government agencies by concerned U.S. Senators, in June. Our thanks to our Senators is belated, but the issue is still current; here's an opportunity to familiarize ourselves with it.
Background
In its 2010 Greenhouse Gas Tailoring Rule, EPA for the first time failed to distinguish biogenic CO2 emissions from fossil fuels and thus did not exclude biogenic CO2 from its Clean Air Act permit program for stationary sources. However, because bioenergy has a uniquely different profile than fossil fuels, in 2011 EPA imposed a three-year deferral of regulating biogenic CO2 pending a scientific review and the development of an Accounting Framework for Biogenic CO2 Emissions from Stationary Sources. EPA’s original draft, Accounting Framework, issued in September 2011, recognized the greenhouse (GHG) gas reduction benefits of bioenergy produced from forest product mill residuals and byproducts. Yet, because the deferral of biogenic emission regulation expired, biogenic CO2 emissions are counted the same as fossil fuel emissions under EPA’s current and proposed greenhouse gas regulations.
On Nov. 19, 2014, after an extensive four-year review, EPA issued its revised draft accounting framework, 14 technical appendices, and a related policy memorandum to EPA’s regional offices.
Key Points from EPA
• In the policy memorandum, EPA makes a preliminary finding that the use of certain forest-derived
industrial byproducts and waste-derived feedstocks for energy is carbon neutral.
• In the appendices, EPA unequivocally finds that black liquor is carbon neutral.
• In addition, EPA indicates that the use of whole trees, or roundwood, for energy may be carbon neutral
so long as they are "sustainably derived," but it is unclear how that determination would be made.
The framework and the accompanying memorandum provide a step in the right direction on the carbon neutrality of some types of biomass; however, the paper and wood products manufacturing industry needs greater certainty regarding the carbon neutrality of some forest products manufacturing residuals, waste-derived biomass, and how EPA will determine whether trees that may be used for energy are "sustainably derived."
Visit http://www.naylornetwork.com/wvf-nwl/pdf/Carbon_Neutrality1.pdf to view the full article online.