On Monday, September 13, 2010, SWANA submitted a comment letter to EPA in response to their Call for Information on Emissions Associated with Bioenergy and other Biogenic Sources (EPA-HQ-OAR-2010-0560). This call for information was initiated to help EPA determine how to regulate biogenic emissions as part of their recently promulgated Tailoring Rule.
EPA’s Tailoring Rule, finalized this summer, is the vehicle EPA intends to use to regulate greenhouse gas emissions from stationary sources. In this rulemaking EPA failed to differentiate between biogenic and anthropogenic carbon dioxide emissions. They cited their reasoning being that there was insufficient time to determine if the regulation of biogenic emissions would increase their regulatory burden. Biogenic emissions are part of the earth’s natural carbon cycle and are carbon neutral. Anthropogenic emissions, however, are caused by human activity (e.g. burning fossil fuels) and involve the release of additional carbon into the atmosphere.
On July 9th, SWANA was one of a number of organizations that
requested EPA reconsider their treatment of biogenic emissions. In response to this letter and requests from other groups EPA announced a Call for Information on Biogenic Emissions.
In our comment letter we cited four specific reasons EPA must reconsider their treatment of biogenic emissions.
• The regulation of biogenic emissions is inconsistent with international and national GHG policies. Even EPA’s own GHG Inventory does not combine anthropogenic and biogenic emissions.
• Waste-based energies are renewable and provide local governments with opportunities to reach their GHG reduction goals with locally available energy.
• On a lifecycle basis, the use of WTE and LFG reduce net emissions of GHG and this must be considered while EPA develops BACT for these sources.
• The use of waste as a feedstock has different net GHG emissions than other biomass sources. Because waste-based energies do not contribute to direct or indirect emissions from land-use changes they are preferable to other forms of biomass based energy.
To read our full letter to EPA please
click here.
For more information on the Call for Information, please see
EPA’s Website.