November 26, 2013
Mr. Joe Goffman Senior Counsel, Office of Air and Radiation, U.S. Environmental Protection Agency1200 Pennsylvania Avenue, N.W. Mail Code: 6101A Washington, DC 20460
Dear Mr. Goffman:
We, the undersigned scientists, believe regulations governing how stationary sources account for biogenic carbon emissions must be based on sound science and ensure adequate protections for forests and the climate. We applaud the EPA for setting a high standard in making policy on this important issue by seeking expert scientific input from the Science Advisory Board (SAB). We now urge the agency to follow through on that process and embrace the central scientific principles underscored by the SAB as you finalize these accounting rules. Doing otherwise at this juncture will fail the test of rigorous, science- based policymaking and could result in regulations that distort the marketplace towards greater use of unsustainable sources of biomass, with significant risks to our climate, forests and the valuable ecosystem services they provide and we rely on.
In 2011, EPA initiated a science-driven process to develop a methodology for properly quantifying biogenic carbon emissions from stationary sources under the Clean Air Act. As part of this process, the agency rightly solicited scientific input by submitting a draft “Accounting Framework for Biogenic CO2 Emissions from Stationary Sources” to the SAB for review by an assembled Biogenic Carbon Emissions Panel. As now EPA finalizes its biogenic carbon accounting rules, it must follow through on that process and adopt the science panel’s key recommendations: 1) moving beyond the flawed assumption that bioenergy is inherently carbon neutral; 2) rejecting the regional accounting method originally proposed in the draft Accounting Framework; and 3) ensuring a scientifically-sound methodology for determining the carbon emissions impact to the atmosphere from burning long-recovery biomass feedstocks—most notably, whole trees.