BIO Asks California for Consistent, Accurate Accounting of Emissions Under Cap-and-Trade Rules
“California’s draft regulation implicitly recognizes that biomass used for power generation recycles atmospheric carbon, resulting in no net carbon emissions. California should ensure that its final regulation consistently applies this rule to all fuels, including liquid transportation biofuels,” stated Brent Erickson, executive vice president of BIO’s Industrial & Environmental Section. “Put simply, a ton of carbon emissions is a ton, and California should not favor or penalize any obligated party through inconsistent treatment of greenhouse gas emissions.”
“Only one option being considered by California in its preliminary draft regulation would apply a consistent accounting of carbon emissions, using common methodology for all industries, including electricity generation, transportation fuels, and other industrial processes,” Erickson continued. “Treating the sectors differently would undermine the ability of obligated parties to reduce the state’s greenhouse gas emissions at costs acceptable to consumers and drivers. Under any cap-and-trade system, lifecycle emission estimates would be directly monetized. Lifecycle emissions are not applied in the accounting for biomass used in electricity generation; to incorporate them for biofuels would unfairly incentivize one form of energy production over another.”
BIO specifically commented on the inclusion of indirect land use change estimates for biofuels under the cap-and-trade regulation, noting that it is already counted in California’s Low Carbon Fuel Standard.
Erickson continued, “Regulatory double jeopardy risks suffocating California’s position in the development of advanced biofuels. Experts and regulatory authorities have not agreed upon a standardized methodology for calculating emissions from indirect land use. California’s draft regulations for the cap-and-trade system should not single out biofuels for inclusion of indirect effects.”
BIO’s comments can be viewed at http://bio.org/letters/.
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