Your Clean Power Plan – Comments on Biomass and the Federal Implementation Plan Due Jan 21

On January 21, the U.S. EPA will close the comment period on the Clean Power Plan's Federal Implementation Plan (FIP) and model trading rules, which the EPA released in draft form in August 2015 when it finalized the Clean Power Plan. The FIP will be required by states that either do not submit state plans, or submit insufficient plans. The model trading rules are to provide a guideline for states, as many states are expected to prepare trading ready plans, so that they may trade emission rate credits or allowances with other states. EPA is also asking for comment on whether biomass should be included in the FIP.

Currently, biomass, as well as combined heat and power (CHP) and demand-side energy efficiency, are not included in the FIP. EPA seeks comment on whether or not these measures should be included in a federal plan. For biomass, EPA also seeks additional comment on what kind of evaluation, measurement and verification (EM&V) should be required to certify that biomass feedstocks provide a benefit to stack emissions. Finally, EPA asks if they should create a list of ‘qualified biomass feedstocks’ for inclusion in the federal plan.

For a deeper discussion of the Clean Power Plan and consideration of the role of biomass in the FIP, please see a recent webinar from the Penn State University Energy Extension, with presentations from EESI Policy Associates Laura Small and Jessie Stolark (apologies for the sound quality –the sound cuts out occasionally).

To comment on these questions, go to regulations.gov. Comments are due January 21.