Biomass Issues:Evolution Since Last Year

2011 FIA User Group MeetingMarch 8-10, Sacramento, CA

Brad Upton, NCASI

Federal GHG Legislation OverviewJune 2009: Waxman-Markey cap and trade

bill passed in House of RepresentativesMarch 2010: Kerry-Boxer cap and trade bill

stalled in SenateApril 2010: Kerry-Lieberman-Graham crafted

less sweeping bill, but did not gain tractionJuly 2010: After several attempts at more

narrow bills the Senate dropped effortsNo climate legislation is expected from 112th

Congress

EPA Actions Towards GHG Regulation (highlights)December 2009: Endangerment Finding –

EPA concludes GHGs endanger public health, welfare

April 2010: Tailpipe Emission Standards – EPA issues new vehicle GHG emission standards applicable to new cars and trucks (equivalent to 35.5 mpg)

June 2010: Tailoring Rule – EPA publishes rule to regulate GHGs from stationary sources under PSD and Title V programsBiogenic CO2 treated no differently from fossil

CO2

Renewable Fuel Standards (RFS2) & Energy Independence and Security Act (EISA)

Finalized December, 2010Includes specific life cycle GHG emission thresholds for

renewable fuels (including land use change)Focused on agricultural biomass rather than forest

biomassEstablished restrictions on the types feedstocks, and

types of land used to grow them, that can be used to make renewable fuel

Forest biomass from federal lands and from silvicultural plots cultivated after December 2007 not eligible

RESULT: Most sources of woody biomass are excluded

Biogenic CO2 “Carbon Neutrality”• An attribute of the biogenic carbon cycle

that enables the GHG mitigation potential of bioenergy systems

• There are several different meanings given to the term “carbon neutrality”

• The controversy surrounding biomass carbon neutrality is partly caused by a lack of a common understanding of the meaning of the term

Atmosphere

BiomassCarbon

Bio

gen

ic C

O2

CO

2

Biogenic carbon is part of a relatively rapid natural cycle that impacts atmospheric CO2

only if the cycle is out of balance

Fos

sil

Fue

l

Atmosphere

Non

-bio

geni

c C

O2

Fossil fuel combustion transfers geologic carbon into the

atmosphere. It is a one-way process

The “neutral” biomass carbon cycle

VS Carbon transfers from geological reserves

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Six Different Concepts of Carbon NeutralityInherent carbon neutrality

The inherent property of biomass reflecting its being part of a natural cycle which, if in balance, has a zero impact on atmospheric greenhouse gases

Carbon cycle neutrality A property of biomass when it is obtained under conditions where forest carbon

stocks remain stable over a given area and time, meaning that the forest carbon cycle is in balance

Life cycle neutrality A property of a product or product system that has zero net emissions over the life

cycle

Offset neutrality A property of a product or product system whose emissions have been offset via

obtaining reductions accomplished outside of the product’s lifecycle

Substitution neutrality A property of a product or product system whose life cycle emissions are equal to

those for all other likely substitute products or product systems

Accounting neutrality The use of an emission factor of zero for biogenic CO2 because the impacts of

biogenic carbon flows are being characterized by calculating changes in stocks of carbon stored in forests and forest products

Carbon Stocks/Land Use ChangesFargione, et al. (Science 319, 1235 (2008)) discussed

carbon debt from land use change due to biomass demand

Searchinger, et al. (Science 326, 527 (2009)) assert that characterizing biogenic CO2 as carbon neutral is improper if land use change is not considered

MANOMET study (June 2010) developed concept of carbon debt based on a plot level analysis of substitution impacts – carbon withdrawals from harvesting are “paid back” over time as regrowth occurs

Sustainable Forest Management: In any given year carbon stock depletion on harvested stands is offset by carbon accumulation on undisturbed stands

Harvested Area

In forests managed sustainably, carbon losses due to harvest are offset by carbon uptake by growing trees.

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Where To Draw Analysis Boundaries?Internationally accepted life cycle analysis

(LCA) standards require the accounting boundaries to extend upstream to the point where “elementary flows” enter the system from the environment

This accounting approach considers flow of CO2 from atmosphere into growing biomass, and flow of CO2 back to environment when biomass is combusted

Supports use of zero emission factor for biomass combustion as long as carbon stock/land use change is considered

EPA Call for Information (CFI) onGHG Emissions from BioenergyGoal: Determine if biogenic CO2 is carbon

neutralSelection of questions from EPA CFI:

Does IPCC approach suggest biomass CO2 is carbon neutral?

Can IPCC approach be applied at smaller scales?

Request for alternative accounting approachesHow to compare biomass energy to fossil

energy Unfortunately, EPA has not defined its

concept of “carbon neutrality”

EPA CFI on Bioenergy…Does IPCC approach suggest biomass CO2 is

carbon neutral?IPCC approach tracks changes in carbon stocks

on land and assigns zero emission factor for biomass combustion CO2

IPCC methods are based on “accounting neutrality” of biomass carbon

Data on forest carbon stocks illustrates that, in the U.S., net flux of carbon is into forest biomass rather than into the atmosphere

Timberland Growth/Removal Ratio By Region

Source: Forest Resources of the United States, 2007 – Table 3613

1.70

1.22 1.05 1.37

-

0.50

1.00

1.50

2.00

2.50

3.00

3.50

4.00

4.50

5.00

1976 1986 1996 2006

North South Rocky Mtn Pacific Coast

North

PacificCoast

South

Rocky Mtn

• Growth-removal ratio is calculated based on annual growth on timberland divided by annual removal as of reported years. No specific data for growth and removal in between reported years.

EPA CFI on Bioenergy…Can IPCC approach be applied at smaller

(than national) scale?At the national scale, “ownership” of forest

biomass is defined by national boundaries – data is available

At the facility level, it is not possible to link wood users to specific areas or land

However, it may be possible to apply IPCC’s guidelines at the regional scale (e.g., state)

Some states (e.g., Washington) and regions (e.g., Western Climate Initiative) have adopted this approach (“carbon cycle” biomass neutrality)

EPA CFI on Bioenergy…EPA request for alternative accounting

approachesIPCC approach (accounting neutrality) can be used

in emissions reportingComparative assessments can be used to identify

policies that ensure stable or increasing forest carbon stocks

Comparative assessments can also be used to evaluate the difference in net carbon emissions for two different scenarios (e.g., two different fuels, two different policies, etc.) Comparative assessments typically include other life

cycle emissions and are described as comparative carbon footprints

EPA CFI on Bioenergy…How should biomass energy be compared to

fossil energy?Comparative carbon footprint studies are

required Life Cycle Assessments (LCA) limited to carbon and

GHGsLand use change should be addressedStandard methods are under development by

ISO and WRI/WBCSDBenefits of forest biomass-based fuels, where

forest carbon stocks are maintained, have been documented

Recent LCA Analyses of BiopowerStudy Biofuel Offset fuel GHG saved

Froese et al. 2010 Forestry Residuals Coal 100%

Mann & Spath 2001 Wood Residuals Coal 123%

Robinson et al. 2003 Forest/Ag Residuals Coal ~95%

Pehnt 2006 Residuals, Energy Crops

Mix 85-95%

Cherubini et al. 2009 Forestry Residuals Various 70-98%

Zhang et al. 2010 Wood Pellets Elec from Coal, Gas

91%, 78%

Raymer 2006 Fuel Wood, Pellets, Residuals

Elec from Coal, Oil

81-98%

Heller et al. 2004 Short Rotation Willow Coal 99%

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EPA GHG Regulation - UPDATEOn January 12, 2011, EPA announced

decision to defer, for three years, GHG permitting requirements for biomass CO2

EPA will use this time to “seek further independent scientific analysis of this complex issue”

EPA received more than 7000 comments on it’s July 2010 Call For Information on bioenergy

Expect EPA guidance to permitting authorities that use of biomass as fuel is BACT for GHG emissions

Federal GHG Legislation - UPDATELegislation introduced in the 112th Congress

to delay or strike down EPA GHG regulationTwo bills in House would invalidate EPA’s

Endangerment Finding, Tailoring rule, PSD regulations, etc.

House bills would also repeal or prevent enforcement of EPA mandatory GHG reporting rule

Other House action (“Continuing Resolution”) cuts off funding for EPA GHG regulations until September 30, 2011 (end of fiscal year)

International Climate NegotiationsSixteenth Conference of the Parties (COP 16),

Cancun Mexico in late 2010Voluntary emission reduction targets for both

developed and undeveloped countriesAgreement to keep temperature increases below

2°C (450 ppm CO2)Monitoring, reporting, and verification (MRV) of

actionsEstablishment of “Global Climate Fund” to finance

adaptation and mitigation measures in developing countries

Advance REDD+ and endorse CDMNo binding targets

State & Regional GHG ProgramsNortheastern Regional Greenhouse Gas Initiative

(RGGI)Ten Northeastern and Mid-Atlantic statesReducing cap on emissions from electric generating

unitsRegulation began in 2009

Western Climate Initiative (WCI)Seven U.S. states and four Canadian provincesEconomy-wide program with planned cap and tradeCalifornia program will take effect in 2012

Midwestern GHG Reduction Accord (Midwestern Accord)Six U.S. states and one Canadian provinceEconomy-wide program with planned cap and tradeScheduled to launch in 2012

SummaryGHG regulating legislation is unlikely from 112th

CongressEPA moving forward with GHG regulation but

deferring permit requirements for biogenic CO2Continuing challenges to use of zero CO2 emission

factor for biomass at point of combustionOnly modest progress in international climate

initiativesState and regional GHG programs are moving forwardMore research is needed to better define the lifecycle

attributes of certain biomass fuel materials, and to improve understanding of carbon accounting concepts