06.16.10 Biomass Letter to EPA Administrator Lisa Jackson

8/8/2019 06.16.10 Biomass Letter to EPA Administrator Lisa Jackson

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Q.nngtv uf ffe lflnit tatwlflfiufingtun, 9, t515June 16, 2 010l, sa JacksonAdmlni stratorEnvironment.al ProtecLion Agency1200 Pennsylvania Ave,, NW, Room 3426 ARNtlashi ngton, DC 20460Dear: Administrator Jackson :

le are writ.ing to express our deep disappointment and concern overthe EPA's decision in its final PSD Tailoring Ru_Ie to depart from thegovernment's consistent past practice of excfuding biomass coLbustionemissions in calcurating cHc emissions. This decision contradicts federalprecedent regarding the carbon neutrality of b.iomass combustion and willdiscourage the responsible development and utilization of renewab.Lebiomass that could and should play a more significant ro.le .in our nation'senergy poticy.The PSD Taiforing Rule defines what stationary sources wiLf besubject to greenhouse gas (GHG) emission controfs and regulat.ions in aphase-.in process beginning on Jnuary 2t 2011. In the draft TailoringRule, the EPA proposed to calculate a source's GHG em.issions relying onthe EPA's fnventory of U.S. Greenhouse Gas Emissions and Sinks. In thefinal rule, EPA ignored its own inventory and equated biogenic cHcenissons with fossil fuel emissons.The EPA' s proposal at a minimum lmpied, if not made it cLear, thatemissions from biomass combustion hroufd not b,e included in the finalTaiLoing Rule because the EPA fn"entory- states biomass combustionemlssions are of "biogenic origin,, and are not currentfy included innationaf emissions totls. The lnventory explcitly excludes biogenlcem.iss.ions because "it ls assumed that the carbon refeased during theconsumption of biomass is recycled as U.S. forests and crops regenerate,causing no net addition to carbon dioxide in the atmosphere.,, The EpA'sreversaf of this establshed position by includj.ng biomass co-bustioilemissions n the final PSD Tailoring Rule appears to directly contradictprevious EPA policy.The decision also contradicts long-standing federaf andinternational precedents. Emissions from the combustion of biomass are notincluded in the Department of Energy's vo.Luntary greenhouse gas emissionsreportinq progrms/ the EPA, s greenhouse qas reportlng rufe/ or

calculations of internationaf bodies incruding the fntergovernmenta f panelon Climate Change and the European Union.Moreover, hthen the House of Representatives passed the AmericanClean Energy and Security bilf (H.R. 2454J n June, 2009, Congressclar:ified that biomass materiaf from both privte and pubic lands quatifyas a renewbfe enerqy source. A similar definition of renewable biomassis included in the recently released discussion draft of Senator Kerry andSenator l,ieberman's American Potrer Act. [^IhiIe imp.rovements should be made

PINTEO ON RECYCLEO PAPEA


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to the definition on federal lands, these definitions cfearly demonstrateCongress's commitment to and support of biomass utilization. EPA's newinterpretation undermines these object.ives by arbitrarily eliminating thegreenhouse gas benefits of biomass compared to conventionaf fossif fuefs.There is enormous potential to generate rener^able energy from waste

products galhered on public and private ands. Thls inc.Ludes byproductsof preventive treatments that are removed to reduce hazardous fue]s, toreduce or. contain disease or insect infestat.ion, or to restore foresthealth.Miflions of acres of public and private forests generate hundreds ofthousands of wood chips, sfash, brush, and thinning each year. currentpractlce is to p]e and burn ths material in the open.

Using biomass to produce local energy in a controlled environment at afacility outfitted with air scrubbers that compfy with the clean Air Actmakes more sense than burning it in the open. Further, th.is would helpstimulate the economies of rural communities surrounded by federal landsby creaLing jobs.lncluding biomass combustion emissions in the final PSD TaiforingRule and potentialfy imposing new regulations on biomass combustlonfacilities will discourage the collection and transportation of woodybiomass from public and private lands. Instead of encouraging i:.herecovery of a clean, carbon neutral energy source from public and privateforests, the EPA's decision will likely resut in the continuation ofburning b,iomass materlal in the open. Beyond the policy and pragmaticramifications of EPA's new decision, it is also inconsistent with andcontradictory to the well established science regarding biomassr:omhn sr i on -

ln liqht of the EPA's declsion to reverse federal and internationa.Iprecedent and ignore cear Congressiona.l intent r:egarding biomassutilizatlon, we respectfully request a written detaild responseexplaining your plan to recons.ider the treatment of emissions of b.iogen.iccarbon dioxide under the PSD and Title V programs. ln particular, wewould like to understand your aqreement with the Secretary of Agricultureto seek further conment on the greenhouse gas benef.its of bioenergy andthe specific timeline when this will take place. tie expect that you wil.Lconduct this review promptly in order to avoid any adverse consequences tobiomass comL'ustion facilities. We urge you to stay the application of therules to such facilities. pending such review.Your written response should include: 1) specific details regardingyour agreement with the Secretary of Agriculture to seek further comnlenton the cHc benefits of bioenergy; 2) a specific timeline detaifing inmonths when this will take place; and 3) whether you will stay theapplication of the rules to biomass combustion facilities pend.ing yourreview.


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fu"fuember of CongressCathyMember cif conqress

Thank you in advanceforward to your timely and for your attention to this matter. We ooksubstanLive response.Sincerely,

,?.hMember of Congress

Ldalt MinnrMember of

Mencer of Congres s

Jonesof Congres s

l^-nCongress g4-Rick LarsenMeber. of Congres s

Bobby ightMember of Congr.es s

Tim HoldenMember of Congres skorr,,-ffiY-^et@illiam owes Frank T,ucas Bart Stupak

Member of Congress

/(-/ //. /, U- rl",,qr-',Michaef M.ichaud Glenn ThompsonMeber of Congress Member of CongressT:s*,w^ember of Congres sA*..Men3er of

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an BorenMember of Congres s

nie Herlseth WaIterr of Congres s

S imdsonof Congress

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7&l?twhomas Perriel.loMefiber of Congr.ess

Roscoe BartlettMember of Congres s

Mke McTntyreMember of Congres s

Chri sMember of Congres s Bob GoodtacteMember of Congress

\^Rick BoucherMeber of Conqres s

l,th'*o BonnerMelcer of Congres s6"pp Mf^Gregg HarperMember of Congre s s

rw"f ?eber of CongressMember of congres s Merber of Congres s

u,n^e^at *l o.'.- EmersonMember ot congressfury(truCq,,Shelley Moore Caprto/dKember of Congres s Tt+n**f

djenny ReneMember of

/- /n/7 ^ /k/h(// i^ Marshal f(---,/ ttembe r ot Congressynthia 1S Member of Congres s

David WuMember of Congres s

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06.16.10 Biomass Letter to EPA Administrator Lisa Jackson

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Transcript of 06.16.10 Biomass Letter to EPA Administrator Lisa Jackson