EPA's 'Tailoring Rule' and the Biomass Industry

Last week, the U.S. Environmental Protection Agency (EPA) issued is final statement for its “tailoring rule” that outlines how the agency will regulate greenhouse gas emissions (GHG) under the Clean Air Act.  The “tailoring rule” determines which polluters will be required to account of their greenhouse gas emissions when the EPA begins to formally regulate the gases beginning in January 2011. The ruling did not exempt biomass-fueled power producers from GHG permitting requirements, which came as a surprise to many in the biomass industry.  The reasoning behind exempting biomass from these requirements is because the combustion of biomass is widely considered “carbon neutral,” in regulation and policy in the United States and abroad.  For example, when wood waste is combusted for energy, it releases carbon dioxide into the atmosphere, which the trees had already adsorbed from the atmosphere when the trees grew.  The assumption is that this released carbon dioxide will be reabsorbed by new trees as they grow naturally.  This carbon neutral consideration is why biomass power plants assume net CO₂ emissions of zero.

Including biomass power plants under the EPA’s tailoring rule is a clear policy shift and may imply a change in position for future policy.  The lack of distinction between renewable biomass as an alternative fuel to traditional fossil fuels like coal, oil, and natural gas means that biomass may no longer be considered more attractive as an option for increasing the nation’s alternative energy portfolio from a carbon emissions perspective.  In the New York Times article, “Biomass Industry Sees ‘Chilling Message in EPA’s Greenhouse Gas Emissions Rule” policy analyst for the Natural Resources Defense Council, Franz Matzner  points out his view that there is an important difference between biomass that increases greenhouse gas emissions (such as trees in a forest) and biomass that leads to reductions such as waste biomass (i.e. agricultural crops, wood waste).  The environmental sustainability of widespread use of forest trees for energy production has been questioned by some policy advocates in recent years and is being actively debated in many policy circles.

Using biomass waste for energy production offers significant environmental benefits.  Real reductions in CO₂ emissions occur when waste is used to replace fossil fuels, instead of being left to decompose in landfills or on fields. When wood waste is left to decompose in landfills, the decaying wood releases methane which is 21 more potent a greenhouse gas than CO₂.  Failing to make the distinction between different types of biomass for energy production threatens to deter efforts to reduce fossil fuel usage for energy production that also have positive benefits for carbon emissions. 

When issuing the final statement on the “tailoring rule,” the EPA stated that it does not have enough evidence to exclude CO₂ emissions from biogenic sources at this time, but that they recognize the issue warrants further explanation, and they plan to seek further comments on addressing the issue.  It is important that the EPA examine this issue further.  Retaining the carbon neutral status of biomass and exempting biomass from the tailoring rule may help to decrease the nation’s reliance on fossil fuel by making use of a domestic renewable resource.  Policymakers must be careful not to create maligned incentives in carbon policy that would stem this transition toward increased renewable fuel use in our nation’s energy mix.