EESI Submits Comments to EPA on Bioenergy and Greenhouse Gas Tailoring Rule

On May 5, the Environmental and Energy Study Institute (EESI) submitted comments to the Environmental Protection Agency (EPA) concerning the agency's proposed action to defer for three years the application of the Clean Air Act Prevention of Significant Deterioration and Title V permitting requirements to biogenic carbon dioxide emissions from major bioenergy facilities and other major biogenic stationary sources of emissions.

EESI supports the EPA’s efforts to regulate carbon dioxide and other greenhouse gas (GHG) emissions from the burning of fossil fuels , but also welcomes the EPA’s decision to delay the regulation of bioenergy facilities in order to further study the life cycle GHG emissions from bioenergy systems. “We do not believe that greenhouse gas emissions from bioenergy producers should be regulated in the same manner as major emitters that use fossil fuels,” wrote EESI executive director, Carol Werner, explaining that emissions from sustainable bioenergy production are “part of a continuously renewable, natural carbon cycle.”

EESI suggested the EPA consider in the interim exempting from future regulation those biomass facilities that use types of biomass for which the climate benefits are undisputed and clearly documented scientifically, such as:

• Annual, short rotation, or perennial energy crops grown on previously farmed lands;
• Urban organic waste and woody biomass diverted from landfills;
• Clean woody biomass construction and demolition debris;
• Woody biomass residues from forest industry operations and production;
• Slash and thinnings from forest ecosystem maintenance and fuel reduction activities;
• Biomass from invasive species removal, treatments of forest infestations and disease, and storm damage; and
• Sustainably harvested residues from agricultural crops and livestock wastes.

Such an exemption would allow farmers, forest owners, bioenergy producers, investors, workers, and communities to move forward and develop these biomass resources and technologies immediately without the cloud of regulatory uncertainty.

Click here to read EESI’s full comments to the EPA.