The Environmental Protection Agency (EPA) is considering equating biogenic carbon emissions with fossil fuel emissions under the Tailoring Rule, which requires the accounting and reporting of greenhouse gas emissions under the Renewable Fuels Standard (RFS2). Biogenic carbon emissions are those that are naturally created during the combustion and decay of woody biomass and up until now, have always been considered carbon neutral by the EPA. As such, the Renewable Fuels Association (RFA) is disputing this clause in the rule.
In a letter to the EPA, RFA wrote, “While RFA generally supports a national policy to address climate change, we believe biogenic emissions must be exempt from GHG accounting schemes and regulatory frameworks. Specifically, inclusion of biogenic GHG emissions in determinations of applicability of the Prevention of Significant Deterioration (“PSD”) or Title V Permitting Programs is not scientifically justified, runs afoul of accepted national and international GHG accounting methods, and is contrary to public policies enacted to encourage development of a robust renewable fuels industry in the United States.”
According the the RFA, it is “indisputable that CO2 emissions resulting from the combustion, fermentation, and decay of biomass, are by nature, carbon neutral in that those emissions are naturally offset when the biomass removes an equivalent amount of CO2 from the atmosphere via photosynthesis during growth.”
Therefore, RFA is calling for the EPA to reconfirm that the carbon neutrality convention for accounting of biogenic GHG emissions is both scientifically justified and appropriate for regulatory contexts. Continue reading