Comments of Biotechnology Industry Organization on EPA’s Science Advisory Board Deliberative Draft Report for Biogenic Carbon Accounting
May 10, 2012
The Biotechnology Industry Organization (BIO) appreciates the opportunity to submit comments on the Environmental Protection Agency’s (EPA) Science Advisory Board’s (SAB) Deliberative Draft Report (Draft) of the Biogenic Carbon Emissions Panel. BIO is the world’s largest biotechnology organization, with over 1,100 member companies worldwide. BIO’s members are the leaders in the development and production of conventional and advanced biofuels, renewable chemical intermediates, bioplastics, and other bioproducts, bioprocesses, biocatalysts, and next generation energy crops, such as switchgrass, miscanthus, short rotation woody crops, and algae.
BIO commends the SAB on its efforts to review and comment on EPA’s Accounting Framework for Biogenic Carbon Emissions from Stationary Sources (Accounting Framework), taking into consideration the scientific and technical issues associated with accounting for emissions of biogenic carbon dioxide (CO2) from stationary sources.
Renewable Biomass Carbon Credit
The treatment of biogenic carbon is a complex issue that is closely tied to the treatment of land use change (LUC). Several metrics are possible for biogenic carbon and these are applied inconsistently among fuel LCA models, for example. BIO is concerned that the complexity of the proposed Accounting Framework may effectually disincentivize the use of sustainable biomass for biofuels, biopower and other forms of bioenergy. Accordingly, we agree with the fears expressed in comments submitted by the Edison Electric Institute and National Alliance of Forest Owners that the complexity of the Framework and the associated regulatory compliance costs may cause some facilities to move away from using biomass even though some biomass sources compare favorably to fossil energy. BIO encourages the EPA and its SAB Panel to work toward streamlining and simplifying the requirements of the Accounting Framework to help better support industry’s efforts to transition to and utilize sustainable biomass, thereby helping to increase U.S. production and use of domestically produced alternative energy in a sustainable manner.
Some of the comments submitted to the SAB, which express concern about the short-term effects of combusting sustainable biomass for biofuels, fail to consider all of the benefits associated with utilizing sustainable biomass for biofuels. Combustion of fossil fuels permanently and irreversibly leads to increased concentrations of CO2 in the atmosphere. Combustion of biofuels and other biogenic energy sources recycles CO2 emissions at different temporal and spatial scales, through renewable biomass feedstocks. If sustainably sourced, such combustion does not result in lasting increases in CO2 concentrations in the atmosphere. As the American Forestry and Paper Association points out in its comments on the Draft, in contrast to fossil fuels, carbon is stored in biomass and after release upon combustion can be recaptured in biomass re-growth.Other uses of biogenic carbon, such as biochemicals and bioplastics, may even sequester CO2, reducing atmospheric GHG concentrations.
The inherent benefits of utilizing renewable biomass feedstocks versus traditional fossil fuel consumption are consistent with federal policies designed to increase U.S. energy security and independence and reduce carbon emissions, and should therefore be recognized in the Accounting Framework. Indeed, when regulating biofuels, life-cycle based methodologies should start from the premise that all renewable biomass receives full credit for recycling carbon. Deviations from this premise should be considered only as consistent with internationally recognized methodologies for taking into account all direct life-cycle emission impacts.