Comments to EPA on Accounting Framework for Biogenic Carbon Dioxide Emissions

Wednesday, October 26, 2011

On July 20th, 2011, EPA published its Final Three-Year Deferral Rule which deferred for three years a requirement for biomass burning facilities to account for their net carbon dioxide (CO2) emissions. EPA plans to conduct an examination of the science associated with biogenic CO2 emissions from bioenergy plants in the next three years, and the Agency has already begun this process.

On October 3rd, 2011, EPA announced the formation of its eighteen-member Science Advisory Board (SAB) that will review and provide independent advice to the Agency on its Accounting Framework for Biogenic CO2 Emissions from Stationary Sources published in September.

On October 18th, 2011, a group of environmental organizations, including The Wilderness Society, provided comments (see below) to EPA on its accounting framework for biogenic CO2. In addition, The Wilderness Society submitted a set of more extensive comments on the same issue (see below), and indicated that EPA’s proposed framework would allow biomass energy expansion that can result in much higher atmospheric carbon levels. Therefore, our comment letter recommended an alternative accounting framework approach for the SAB to consider (see the comments).