UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

 WASHINGTON D.C. 20460

OFFICE OF THE ADMINISTRATOR

SCIENCE ADVISORY BOARD

September 28, 2012

EPA-SAB-12-011

The Honorable Lisa P. Jackson

Administrator

U.S. Environmental Protection Agency

1200 Pennsylvania Avenue, N.W.

Washington, D.C. 20460

Subject: SAB Review of EPA’s Accounting Framework for Biogenic CO2 Emissions from 

Stationary Sources (September 2011)

Dear Administrator Jackson:

EPA’s Science Advisory Board (SAB) was asked by the EPA’s Office of Air and Radiation to review 

and comment on the EPA’s Accounting Framework for Biogenic CO2 Emissions from Stationary 

Sources (Framework, September 2011). The Framework considers the scientific and technical issues 

associated with accounting for emissions of biogenic carbon dioxide (CO2) from stationary sources and 

develops a method to adjust the stack emissions from stationary sources using biological material based 

on the induced changes in carbon stocks on land (in soils, plants and forests). 

Assessing the greenhouse gas implications of using biomass to produce energy is a daunting task and the 

EPA is to be commended for its effort. The context for the Framework arose when the EPA established 

thresholds for greenhouse gas emissions from stationary sources for the purposes of Clean Air Act 

permits under the New Source Review (Prevention of Significant Deterioration program) and Title V 

operations program. The agency needed to consider how to include biogenic emissions in determining 

whether thresholds for regulation have been met. In July 2011, the EPA deferred the application of 

permitting requirements to biogenic carbon dioxide emissions from bioenergy and other biogenic 

stationary sources for three years, while conducting a detailed examination of the issues associated with 

biogenic CO2. 

The agency sought a method of “adjusting” biogenic carbon emissions from stationary sources to credit 

those emissions with carbon uptake during sequestration or, alternatively, avoided emissions from 

natural decay (e.g., from residues and waste materials). Without a way of adjusting those emissions, the 

agency’s options would be either a categorical inclusion (treating biogenic feedstocks as equivalent to 

fossil fuels) or a categorical exclusion (excluding biogenic emissions from determining applicability 

thresholds for regulation). The purpose of the Framework was to propose a method for calculating the 

adjustment, or a Biogenic Accounting Factor (BAF) for biogenic feedstocks, based on their interaction 

with the carbon cycle. The BAF is an accounting term developed in the Framework to denote the offset 

to total emissions (mathematical adjustment) needed to reflect a biogenic feedstocks’ net greenhouse gas 
emissions after taking into account its offsite sequestration, in biomass or land, or avoided emissions. 

Avoided emissions are emissions that would occur anyway without removal of the feedstock for 

bioenergy. 

The SAB was asked to comment on the science and technical issues relevant to accounting for biogenic 

CO2 emissions. We found the issues are different for each feedstock category and sometimes differ 

within a category. Forest-derived woody biomass stands out uniquely for its much longer rotation period 

than agricultural (short-rotation) feedstocks. The Framework includes most of the elements that would 

be needed to gauge changes in CO2 emissions; however, the reference year approach employed does not 

provide an estimate of the additional emissions and the sequestration changes in response to biomass 

feedstock demand. Estimating additionality, i.e., the extent to which forest stocks would have been 

growing or declining over time in the absence of harvest for bioenergy, is essential, as it is the crux of 

the question at hand. To do so requires an anticipated baseline approach. Because forest-derived woody 

biomass is a long-rotation feedstock, the Framework would need to model a “business as usual” scenario 

along some time scale and compare that carbon trajectory with a scenario of increased demand for 

biomass. Although this would not be an easy task, it would be necessary to estimate carbon cycle 

changes associated with the biogenic feedstock. In addition, an anticipated baseline would be needed to 

estimate additional changes in soil carbon stock over time. In general the Framework should provide a 

means to estimate the effect of stationary source biogenic feedstock demand, on the atmosphere, over 

time, comparing a scenario with the use of biogenic feedstocks to a counterfactual scenario without the 

use of biogenic feedstocks. In the attached report, the SAB provides some suggestions for an 

“anticipated baseline” approach while acknowledging the uncertainty and difficulty associated with 

modeling future scenarios. 

For agricultural feedstocks, the variables in the Framework capture most of the factors necessary for 

estimating the carbon change associated with the feedstock use. For short rotation agricultural 

feedstocks where carbon accumulation occurs within one to a few years, the Framework can, with some 

adjustments to address estimation problems (including an anticipated baseline for soil carbon changes) 

and careful consideration of data and implementation, represent direct carbon changes in a particular 

region. As recognized by the agency, for many waste feedstocks (municipal solid waste, construction 

and demolition waste, industrial wastes, manure, tire-derived wastes and wastewater), combustion to 

produce energy releases CO2 that would have otherwise been returned to the atmosphere from the 

natural decay of waste. The agency chose not to model natural decomposition in the Framework; 

however, modeling the decay of agricultural and forest residues based on their alternate fate (e.g., 

whether the materials would have been disposed in a controlled or uncontrolled landfill or left on site, or 

subject to open burning) could be incorporated to improve scientific accuracy. 

The Framework does not discuss the different time scales inherent in the carbon cycle nor does it 

characterize potential intertemporal tradeoffs associated with the use of biogenic feedstocks. However 

the SAB recommends that intertemporal tradeoffs be made transparent in the Framework for 

policymakers. For forest-derived roundwood, carbon debts and credits can be created in the short run 

with increased harvesting and planting respectively but in the long run, net climate benefits can accrue 

with net forest growth. While it is clear that the agency can only regulate emissions, its policy choices 

about regulating emissions will be better informed with consideration of the temporal distribution of 

biogenic emissions and associated carbon sequestration or avoided emissions. 

The SAB was asked whether we supported EPA’s distinction between policy and technical 

considerations. We do not. In fact, the lack of information in the Framework on EPA’s policy context 

and the menu of options made it more difficult to fully evaluate the Framework. Because the 
reasonableness of any accounting system depends on the regulatory context to which it is applied, the 

Framework should describe the Clean Air Act motivation for this proposed accounting system, 

including how the agency regulates point sources for greenhouse gases and other pollutants. This SAB 

review would have been enhanced if the agency had made explicit all Clean Air Act policy options for 

regulating greenhouses gases, including any potential implementation of carbon offsets or certification 

of sustainable forestry practices, as well as its legal boundaries regarding upstream and downstream 

emissions.

Overall, the SAB found that quantification of most components of the Framework has uncertainties, 

technical difficulties, data deficiencies and implementation challenges. These issues received little 

attention in the Framework, but are important considerations relevant to scientific integrity and 

operational efficiency. Moreover, the agency should consider consistency between biogenic carbon 

accounting and fossil fuel emissions accounting. Ideally both fossil fuels and biogenic feedstocks should 

be subject to the same emissions accounting. While there are no easy answers to accounting for the 

greenhouse gas implications of bioenergy, further consideration of the issues raised by the SAB and 

revisions to the Framework could result in more scientific rigor in accounting for biogenic emissions. 

One SAB Panel member expressed a dissenting opinion and recommended that the agency abandon the 

Framework altogether and instead choose to exempt biogenic CO2 emissions from greenhouse gas 

regulation so long as aggregate measures of land-based carbon stocks are steady or increasing. This 

dissenting opinion is based on an accounting guideline from the Intergovernmental Panel on Climate 

Change (IPCC) which recommends that emissions from bioenergy be accounted for in the forestry 

sector. This is not the general consensus view of the SAB. The IPCC approach to carbon accounting 

would not allow for a causal connection to be made between a stationary facility using a biogenic 

feedstock and the source of that feedstock, and thus cannot be used for permit granting purposes. Also, 

the IPCC approach would not capture the marginal effect of increased biomass harvesting for bioenergy 

on atmospheric carbon levels. 

The SAB found a number of important limitations in the Framework, including the lack of definition of 

several key features, such that the Framework’s implementation remains ambiguous. Also, the 

Framework does not incorporate the three feedstock groupings into the details of the methodology or the 

case studies, thus limiting useful evaluation. The Framework also does not discuss the likely event of 

unintended consequences. 

The SAB was not asked to recommend alternatives to the Framework but given the challenges 

associated with improving and implementing the Framework, the SAB recommends that EPA consider

developing default BAFs by feedstock category and region. Under EPA’s current Framework, facilityspecific BAFs would be calculated to reflect the incremental carbon cycle and net emissions effects of a 

facility’s use of a biogenic feedstock. Rather than trying to calculate a BAF at the facility-level, a default 

BAF could be calculated for each feedstock category, and might vary by region, prior land use and 

current land management practices. The defaults would also have administrative advantages in that they 

would be easier to implement and update. Facilities could also be given the option of demonstrating a 

lower BAF for their feedstocks. 

The SAB acknowledges that practical considerations will weigh heavily in the agency’s decision 

making. In fact, any method that might be adopted or considered, including methods proposed by the 

SAB, should be subject to an evaluation of the costs of compliance and the carbon emissions savings 

likely to be achieved as compared to both a categorical inclusion and a categorical exclusion. 

Uncertainties in the assessment of both the costs and the emissions savings should be analyzed and used 

to inform the choice of policy.
The SAB appreciates the opportunity to provide advice on the Framework and looks forward to your 

response.

Sincerely,

/Signed/ /Signed/

Deborah L. Swackhamer, Ph.D.

Chair

Science Advisory Board

Madhu Khanna, Ph.D.

Chair

Biogenic Carbon Emissions Panel

Enclosure
i

U.S. Environmental Protection Agency

Science Advisory Board

Biogenic Carbon Emissions Panel

CHAIR

Dr. Madhu Khanna, Professor, Department of Agricultural and Consumer Economics, University of 

Illinois at Urbana-Champaign, Urbana, IL

MEMBERS

Dr. Robert Abt, Professor of Forestry, Department of Forestry and Environmental Resources, College 

of Natural Resources, North Carolina State University, Raleigh, NC

Dr. Morton Barlaz, Professor, Civil, Construction, and Environmental Engineering, Engineering, North 

Carolina State University, Raleigh, NC

Dr. Richard Birdsey, Program Manager, Climate, Fire, and Carbon Cycle Sciences, Northern Research 

Station, USDA Forest Service, Newtown Square, PA

Dr. Marilyn Buford, National Program Leader, Silviculture Research, Research & Development, 

USDA Forest Service, Washington, DC

Dr. Mark Harmon, Professor and Richardson Chair, College of Forestry, Oregon State University, 

Corvallis, OR

Dr. Jason Hill, Assistant Professor, Bioproducts and Biosystems Engineering, College of Food, 

Agricultural and Natural Resource Sciences, University of Minnesota, St. Paul, MN

Dr. Stephen Kelley, Professor and Department Head, Forest Biomaterials, College of Natural 

Resources, North Carolina State University, Raleigh, NC

Dr. Richard Nelson, Director and Department Head, Engineering Extension Programs, Kansas State 

University Center for Sustainable Energy, Manhattan, KS 

Dr. Lydia Olander, Director, Ecosystem Services Program, Nicholas Institute for Environmental Policy 

Solutions, Duke University, Durham, NC

Dr. John Reilly, Senior Lecturer and Co-Director, Joint Program on the Science and Policy of Global 

Change, Center for Environmental Policy Research, E19-439L, Massachusetts Institute of Technology, 

Cambridge, MA

Dr. Charles Rice, Distinguished Professor, Department of Agronomy, Soil Microbiology, Kansas State 

University, Manhattan, KS

Dr. Steven Rose, Senior Research Economist, Energy and Environmental Analysis Research Group, 

Electric Power Research Institute, Palo Alto, CA
ii

Dr. Daniel Schrag, Professor of Earth and Planetary Sciences, Harvard University, Cambridge, MA

Dr. Roger Sedjo,

*

Senior Fellow and Director of the Center for Forest Economics and Policy Program, 

Resources for the Future, Washington, DC

Dr. Ken Skog, Supervisory Research Forester, Economics and Statistics Research, Forest Products 

Laboratory, USDA Forest Service, Madison, WI

Dr. Tristram West, Ecosystem Scientist, Joint Global Change Research Institute, University of 

Maryland, College Park, MD

Dr. Peter Woodbury, Senior Research Associate, Department of Crop and Soil Sciences, College of 

Agriculture and Life Sciences, Cornell University, Ithaca, NY

SCIENCE ADVISORY BOARD STAFF

Dr. Holly Stallworth, Designated Federal Officer, U.S. Environmental Protection Agency, Washington, 

DC 20460

 

* Dr. Sedjo provided a dissenting opinion (See Appendix E.) 
iii

U.S. Environmental Protection Agency

Science Advisory Board

CHAIR

Dr. Deborah L. Swackhamer, Professor, Hubert H. Humphrey School of Public Affairs and CoDirector of the Water Resources Center, University of Minnesota, St. Paul, MN

SAB MEMBERS

Dr. George Alexeeff, Director, Office of Environmental Health Hazard Assessment, California 

Environmental Protection Agency, Oakland, CA

Dr. David T. Allen, Professor, Department of Chemical Engineering, University of Texas, Austin, TX

Dr. Pedro Alvarez, Department Chair and George R. Brown Professor of Engineering, Department of 

Civil & Environmental Engineering, Rice University, Houston, TX

Dr. Joseph Arvai, Svare Chair in Applied Decision Research, Institute for Sustainable Energy, 

Environment, & Economy, Haskayne School of Business, University of Calgary, Calgary, Alberta, 

Canada

Dr. Claudia Benitez-Nelson, Full Professor and Director of the Marine Science Program, Department 

of Earth and Ocean Sciences, University of South Carolina, Columbia, SC

Dr. Patricia Buffler, Professor of Epidemiology and Dean Emerita, Department of Epidemiology, 

School of Public Health, University of California, Berkeley, CA

Dr. Ingrid Burke, Director, Haub School and Ruckelshaus Institute of Environment and Natural 

Resources, University of Wyoming, Laramie, WY

Dr. Thomas Burke, Professor and Jacob I. and Irene B. Fabrikant Chair in Health, Risk and Society 

Associate Dean for Public Health Practice, Johns Hopkins Bloomberg School of Public Health, Johns 

Hopkins University, Baltimore, MD

Dr. Terry Daniel, Professor of Psychology and Natural Resources, Department of Psychology, School 

of Natural Resources, University of Arizona, Tucson, AZ

Dr. George Daston, Victor Mills Society Research Fellow, Product Safety and Regulatory Affairs, 

Procter & Gamble, Cincinnati, OH

Dr. Costel Denson, Managing Member, Costech Technologies, LLC, Newark, DE

Dr. Otto C. Doering III, Professor, Department of Agricultural Economics, Purdue University, W. 

Lafayette, IN
iv

Dr. Michael Dourson, President, Toxicology Excellence for Risk Assessment, Cincinnati, OH

Dr. David A. Dzombak, Walter J. Blenko, Sr. University Professor of Environmental Engineering, 

Department of Civil and Environmental Engineering, College of Engineering, Carnegie Mellon 

University, Pittsburgh, PA

Dr. T. Taylor Eighmy, Senior Vice President for Research, Office of the Vice President for Research, 

Texas Tech University, Lubbock, TX

Dr. Elaine Faustman, Professor and Director, Institute for Risk Analysis and Risk Communication, 

School of Public Health, University of Washington, Seattle, WA

Dr. John P. Giesy, Professor and Canada Research Chair, Veterinary Biomedical Sciences and 

Toxicology Centre, University of Saskatchewan, Saskatoon, Saskatchewan, Canada

Dr. Jeffrey K. Griffiths, Professor, Department of Public Health and Community Medicine, School of 

Medicine, Tufts University, Boston, MA

Dr. James K. Hammitt, Professor, Center for Risk Analysis, Harvard University, Boston, MA

Dr. Barbara L. Harper, Risk Assessor and Environmental-Public Health Toxicologist, and Division 

Leader, Hanford Projects, and Program Manager, Environmental Health, Department of Science and 

Engineering, Confederated Tribes of the Umatilla Indian Reservation (CTUIR), West Richland, WA

Dr. Kimberly L. Jones, Professor and Chair, Department of Civil Engineering, Howard University, 

Washington, DC

Dr. Bernd Kahn, Professor Emeritus and Associate Director, Environmental Radiation Center, Georgia 

Institute of Technology, Atlanta, GA

Dr. Agnes Kane, Professor and Chair, Department of Pathology and Laboratory Medicine, Brown 

University, Providence, RI

Dr. Madhu Khanna, Professor, Department of Agricultural and Consumer Economics, University of 

Illinois at Urbana-Champaign, Urbana, IL

Dr. Nancy K. Kim, Senior Executive, Health Research, Inc., Troy, NY

Dr. Cecil Lue-Hing, President, Cecil Lue-Hing & Assoc. Inc., Burr Ridge, IL

Dr. Judith L. Meyer, Professor Emeritus, Odum School of Ecology, University of Georgia, Lopez 

Island, WA

Dr. James R. Mihelcic, Professor, Civil and Environmental Engineering, University of South Florida, 

Tampa, FL
v

Dr. Christine Moe, Eugene J. Gangarosa Professor, Hubert Department of Global Health, Rollins 

School of Public Health, Emory University, Atlanta, GA

Dr. Horace Moo-Young, Dean and Professor, College of Engineering, Computer Science, and 

Technology, California State University, Los Angeles, CA

Dr. Eileen Murphy, Director of Research and Grants, Ernest Mario School of Pharmacy, Rutgers 

University, Piscataway, NJ

Dr. James Opaluch, Professor and Chair, Department of Environmental and Natural Resource 

Economics, College of the Environment and Life Sciences, University of Rhode Island, Kingston, RI

Dr. Duncan Patten, Director, Montana Water Center, and Research Professor, Hydroecology Research 

Program, Department of Land Resources and Environmental Sciences, Montana State University, 

Bozeman, MT

Dr. Stephen Polasky, Fesler-Lampert Professor of Ecological/Environmental Economics, Department 

of Applied Economics, University of Minnesota, St. Paul, MN

Dr. C. Arden Pope, III, Professor, Department of Economics, Brigham Young University, Provo, UT

Dr. Stephen M. Roberts, Professor, Department of Physiological Sciences, Director, Center for 

Environmental and Human Toxicology, University of Florida, Gainesville, FL

Dr. Amanda Rodewald, Professor of Wildlife Ecology, School of Environment and Natural Resources, 

The Ohio State University, Columbus, OH

Dr. Jonathan M. Samet, Professor and Flora L. Thornton Chair, Department of Preventive Medicine,

Keck School of Medicine, University of Southern California, Los Angeles, CA

Dr. James Sanders, Director and Professor, Skidaway Institute of Oceanography, Savannah, GA

Dr. Jerald Schnoor, Allen S. Henry Chair Professor, Department of Civil and Environmental 

Engineering, Co-Director, Center for Global and Regional Environmental Research, University of Iowa, 

Iowa City, IA

Dr. Gina Solomon, Deputy Secretary for Science and Health, Office of the Secretary, California 

Environmental Protection Agency, Sacramento, CA

Dr. Daniel O. Stram, Professor, Department of Preventive Medicine, Division of Biostatistics, 

University of Southern California, Los Angeles, CA

Dr. Peter S. Thorne, Director, Environmental Health Sciences Research Center and Professor and 

Head, Departmment of Occupational and Environmental Health, College of Public Health, University of 

Iowa, Iowa City, IA

Dr. Paige Tolbert, Professor and Chair, Department of Environmental Health, Rollins School of Public 

Health, Emory University, Atlanta, GA
vi

Dr. John Vena, University of Georgia Foundation Professor in Public Health and Head, Department of 

Epidemiology and Biostatistics, Georgia Cancer Coalition Distinguished Scholar, College of Public 

Health , University of Georgia, Athens, GA

Dr. Robert Watts, Professor of Mechanical Engineering Emeritus, Tulane University, Annapolis, MD

Dr. R. Thomas Zoeller, Professor, Department of Biology, University of Massachusetts, Amherst, MA

SCIENCE ADVISORY BOARD STAFF

Dr. Angela Nugent, Designated Federal Officer, U.S. Environmental Protection Agency, Washington, 

DC 
vii

NOTICE

This report has been written as part of the activities of the EPA Science Advisory Board (SAB), a

public advisory group providing extramural scientific information and advice to the Administrator and 

other officials of the Environmental Protection Agency. The SAB is structured to provide balanced, 

expert assessment of scientific matters related to problems facing the agency. This report has not been 

reviewed for approval by the agency and, hence, the contents of this report do not necessarily represent 

the views and policies of the Environmental Protection Agency, nor of other agencies in the Executive 

Branch of the Federal government, nor does mention of trade names of commercial products constitute a 

recommendation for use. Reports of the SAB are posted on the EPA website at http://www.epa.gov/sab.
viii

TABLE OF CONTENTS

List of Figures..........................................................................................................................................................ix

Acronyms and Abbreviations..................................................................................................................................x

1. EXECUTIVE SUMMARY.................................................................................................................................1

2. INTRODUCTION.............................................................................................................................................11

3. RESPONSES TO EPA’s CHARGE QUESTIONS........................................................................................13

3.1. THE SCIENCE OF BIOGENIC CO2 EMISSIONS .............................................................................. 13

3.2. BIOGENIC CO2 ACCOUNTING APPROACHES............................................................................... 17

3.3. METHODOLOGICAL ISSUES ........................................................................................................ 19

3.4. ACCOUNTING FRAMEWORK ....................................................................................................... 27

3.5. CASE STUDIES............................................................................................................................ 38

3.6. OVERALL EVALUATION ............................................................................................................. 40

4. DEFAULT BAFs BASED ON FEEDSTOCK CATEGORIES.....................................................................44

REFERENCES .......................................................................................................................................................45

APPENDIX A: Charge to the Panel ................................................................................................................. A-1

APPENDIX B: Temporal Changes in Stand Level Biogenic Emissions Versus Fossil Emissions...............B-1

APPENDIX C: Fate of Landscape Residue after Harvest and System Storage of Carbon......................... C-1

APPENDIX D: Carbon Balances over Time in an Existing Forest System .................................................. D-1

APPENDIX E: Dissenting Opinion from Dr. Roger Sedjo..............................................................................E-1
ix

List of Figures

Figure B-1: Surface temperature change from biogenic emissions versus fossil fuel over time. 

Adapted from Cherubini et al. (2012) and reprinted with copyright permission. .............. B-2

Figure C-1: Fate of residue/slash left after harvest as function of k and time since harvest. ................ C-1

Figure C-2: Landscape average store of residue/slash as function of k and harvest interval. ............... C-2

Figure D-1: Changes in carbon stores of major forest ecosystem pools when a 50 year clear-cut 

harvest system is established and continued. The result is a continued carbon balance. ... D-2

Figure D-2: Changes in carbon stores of major forest ecosystem pools when a 50 year clear-cut 

harvest system is replaced by a 25 year clear-cut harvest system in 2010. The result is a 

carbon debt. ........................................................................................................................ D-3

Figure D-3: Changes in carbon stores of major forest ecosystem pools when a 50 year clear-cut 

harvest system is replaced by a 100 year clear-cut harvest system in 2010. The result 

is a carbon gain................................................................................................................... D-4
x

Acronyms and Abbreviations

AVOIDEMIT 

BAF

BAU

CH4

CO2

CO2e

DOE

EPA

FASOM

GHG

GROW

GtC/y

GTMM

GTP

GWP

GWPbio

I

K

LAR

LEAK

N2O

NSR

PRODC

PSD

RPA

SAB

SEQP

SITE_TNC

SRTS

USDA

Avoided Emissions

Biogenic Accounting Factor

Business as Usual

Methane

Carbon Dioxide

Carbon Dioxide Equivalent

Department of Energy

Environmental Protection Agency

Forestry and Agricultural Sector Optimization Model

Greenhouse gases

Growth

Gigatons of carbon per year

Global Timber Market Model

Global Temperature Potential

Global Warming Potential

Global Warming Potential of biomass

Carbon Input

Proportion of Carbon Lost per unit of time

Level of Atmospheric Reduction

Leakage

Nitrous Oxide

New Source Review

Carbon in Products

Prevention of Significant Deterioration

Resources Planning Act

Science Advisory Board

Sequestered Fraction

Total Net Change in Site Emissions

Sub-regional Timber Supply Model

United States Department of Agriculture
1

1. EXECUTIVE SUMMARY

Biogenic CO2 emissions from bioenergy are generated during the combustion or decomposition of 

biologically-based material. Biogenic feedstocks differ from fossil fuels in that they may be replenished 

in a continuous cycle of planting, harvesting and regrowth. The same plants that provide combustable 

feedstocks for electricity generation also sequester carbon from the atmosphere. Plants convert raw 

materials present in the ecosystem such as carbon from the atmosphere and inorganic minerals and 

compounds from the soil (including nitrogen, potassium, and iron) and make these elemental nutrients 

available to other life forms. Carbon is returned to the atmosphere by plants and animals through 

decomposition and respiration and by industrial processes, including combustion. Biogenic CO2 is 

emitted from stationary sources through a variety of energy-related and industrial processes. Thus, the 

use of biogenic feedstocks results in both carbon emissions and carbon sequestration. 

EPA’s Accounting Framework for Biogenic CO2 Emissions from Stationary Sources (Framework,

September 2011) explores the scientific and technical issues associated with accounting for emissions of 

biogenic carbon dioxide (CO2) from stationary sources and develops a method to adjust the stack 

emissions from bioenergy based on the induced changes in carbon stocks on land (in soils, plants and 

forests). The context for the Framework is the treatment of biogenic CO2 emissions in stationary source 

regulation given the unique feature of plant biomass in providing uptake of carbon dioxide (CO2) from 

the atmosphere during the photosynthesis. Under the Clean Air Act, major new sources of certain air 

pollutants, defined as “regulated New Source Review (NSR) pollutants” and major modifications to 

existing major sources are required to obtain a permit. The set of conditions that determine which 

sources and modifications are subject to the agency’s permitting requirements are referred to as 

“applicability” requirements. Since greenhouse gases are included in the definition of a “regulated NSR 

pollutant,” EPA has to make a determination about whether a source meets the “applicability threshold” 

to trigger permitting requirements. As of January 2011, for facilities already covered by the Prevention 

of Significant Deterioration (PSD) or Clean Air Act Title V programs, greenhouse gas emission 

increases of 75,000 tons per year (tpy) or more, on a carbon dioxide equivalent (CO2e) basis, would be 

subject to technology requirements under the PSD program. As of July 1, 2011, more facilities became 

subject to regulation based on their greenhouse gas emissions. Specifically new and existing stationary 

sources (that are not already covered by the PSD or Title V programs) that emit greenhouse gas

emissions of at least 100,000 tpy became subject to greenhouse gas regulation even if they do not exceed 

the permitting thresholds for any other pollutant. The question before the agency, and hence, the

motivation for the Framework, is whether and how to consider biogenic greenhouse gas emissions in 

determining these thresholds for permitting. The SAB’s consensus advice is highlighted in this 

Executive Summary with more details in the attached report. A dissenting opinion is found in 

Attachment E. 

Evaluation of the Underlying Science 

The SAB was asked to comment on the Framework’s assessment and characterization of the underlying 

science and the implications for biogenic CO2 accounting. EPA has accurately captured the global 

carbon cycle’s flows and pools of carbon. The Framework does an admirable job describing the task of 

quantifying the impact of transforming biologically based carbon from a terrestrial storage pool (such as 

aboveground biomass) into CO2 via combustion, decomposition or processing at a stationary source. At 

the same time, there are several important scientific issues that are not addressed in the Framework. 
2

Time scale

The Framework seeks to determine annual changes in emissions and sequestration rather than 

assessing the manner in which these changes will impact the climate over longer periods of time. 

In so doing, it does not consider the different ways in which use of bioenergy impacts the carbon 

cycle and global temperature over different time scales. Nor does it consider temporal 

differences of climate effects on the environment. Some recent studies have shown that there 

could be intertemporal tradeoffs with the use of long rotation feedstocks that should be 

highlighted for policymakers. In the short/medium run, at the forest stand level, there can be a 

lag time between emissions (through combustion) and sequestration (through regrowth) with the 

use of forest biomass. At the landscape level, there can be concurrent debts and credits with 

harvesting and planting. The impacts of the temporal pattern on climate response depend on the 

metric used for measuring climate impacts and the time horizon being considered. Some 

modeling exercises have shown that the probability of limiting warming to or below 2°C in the 

twenty-first century is dependent upon cumulative emissions by 2050 (Meinshausen et al. 2009). 

This suggests that an early phase of elevated emissions from forest biomass could reduce the 

odds of limiting climate warming to 2°C in the near term. On the other hand, the use of forest 

biomass to displace fossil energy with forest regrowth rates that match harvest rates could leave 

cumulative emissions unchanged over a 100 year horizon and thereby have minimal effect on 

peak warming rates 100 years later as compared to the use of fossil energy (Allen et al. 2009; 

NRC 2011; Cherubini et al. 2012). If the climate effect of biogenic feedstocks is explored, the 

degree to which biogenic feedstocks curtail fossil fuel use should be assessed and quantified. In 

addition, the net accumulation of forest and soil carbon over a 100 year period should not be 

assumed to occur automatically or be permanent; rather growth and accumulation should be 

monitored and evaluated for changes resulting from management, market forces or natural 

causes. 

An accounting framework that incorporates consideration of time will result in a Biogenic 

Accounting Factor (BAF) estimate that depends on the time horizon chosen for measuring the 

climate impact and recognition of the benefits from displacing fossil fuels. Given the slow 

response of the carbon and climate system, if biogenic feedstocks displace the use of fossil fuels 

for longer than 100 years, then there may be a beneficial climate effect. In contrast, if the use of 

biogenic feedstocks does not displace fossil fuels, then any presumed beneficial climate 

consequences of biogenic carbon may be overestimated. 

Spatial Scale

The use of unspecified “regions” as fuelsheds in combination with a reference year baseline is a 

central weakness of the Framework with respect to forest-derived feedstocks. The EPA used a 

variable for the Level of Atmospheric Reduction (LAR) to capture the proportion of potential 

gross emissions that are offset by sequestration during feedstock growth, however the calculation 

of LAR captures landscape wide changes rather than facility-specific carbon emissions 

associated with actual fuelsheds. As a result, the estimates of the BAFs are sensitive to the choice 

of the spatial region as shown in the agency’s own case study. 
3

Intergovernmental Panel on Climate Change Approach 

The SAB was asked whether we agreed with the EPA’s concerns about applying the Intergovernmental 

Panel on Climate Change (IPCC) approach to biogenic CO2 emissions at individual stationary sources. 

The IPCC provides guidelines for countries to estimate and report all of their anthropogenic greenhouse 

gas emissions to the United Nations in a consistent manner. In these guidelines, biogenic CO2 emissions 

were assigned to the land areas where carbon is stored, regardless of where the emissions actually take 

place. The application of the IPCC approach would lead to the outcome that biogenic CO2 emissions at 

stationary facilities are considered part of the land-based accounts assigned to landowners and, hence, 

stationary source facilities would not be held responsible. The SAB agrees with the agency that this 

approach would not be appropriate because it does not allow a link between the stationary source that is 

using biomass feedstocks and the emissions that are being measured. This link is critical in order to be 

able to regulate emissions at a stationary source level which is the way that greenhouse gas emissions 

are mandated to be regulated under the Clean Air Act. To adjust the stack emissions from stationary 

facility bioenergy based on the induced changes off-site in carbon stocks on land, a chain of custody has 

to be established with the source of the feedstock. Furthermore, while the IPCC approach can be used to 

determine if stock of carbon is increasing or decreasing over time, it cannot be used to determine the net 

impact of using a biogenic feedstock on carbon emissions as compared to what the emissions would 

have been if the feedstock had not been used. In order to adjust the emissions of a stationary facility 

using biogenic material it is important to know the net impact of that facility on carbon emissions –

which requires knowing what the emissions would have been without the use of bioenergy and 

comparing it with emissions with the use of bioenergy. If EPA were to apply the IPCC approach, as long 

as carbon stocks are increasing, bioenergy would be considered carbon neutral. Under this approach, 

forest carbon stocks may be increasing less with the use of bioenergy than without but forest biomass 

would still be considered carbon neutral. Application of the IPCC accounting approach is not conducive 

to considering the incremental effect of bioenergy on carbon emissions. 

Categorical Inclusion or Exclusion 

The SAB was asked whether we agreed with EPA’s conclusion that the categorical approaches 

(inclusion and exclusion) are inappropriate for regulatory purposes based on the characteristics of the 

carbon cycle. A categorical inclusion would treat all biogenic carbon emissions at the combustion 

source as equivalent to fossil fuel emissions, while a categorical exclusion would exempt biogenic 

carbon emissions from greenhouse gas regulation. The agency rejected both extremes and asked the 

SAB whether it supported their conclusion that a priori categorical approaches are inappropriate for the 

treatment of biogenic carbon emissions. 

The decision about a categorical inclusion or exclusion will likely involve many considerations that fall 

outside the SAB’s scientific purview such as legality, feasibility and, possibly, political will. The SAB 

cannot speak to the legal or regulatory complexities that could accompany any policy on biogenic 

carbon emissions but this Advisory offers some scientific observations that may inform the 

Administrator’s policy decision. 

Carbon neutrality cannot be assumed for all biomass energy a priori. There are circumstances in which 

biomass is grown, harvested and combusted in a carbon neutral fashion but carbon neutrality is not an 

appropriate a priori assumption; it is a conclusion that should be reached only after considering a 

particular feedstock’s production and consumption cycle. There is considerable heterogeneity in 
4

feedstock types, sources and production methods and thus net biogenic carbon emissions will vary 

considerably. Of course, biogenic feedstocks that displace fossil fuels do not have to be carbon neutral to 

be better than fossil fuels in terms of their climate impact. 

Given that some biomass could have positive net emissions, a categorical exclusion would exempt the 

stationary source from the responsibility of controlling CO2 emissions from its use of biogenic material 

and provide no incentive for the development and use of best management practices. Conversely, a

categorical inclusion would provide no incentive for using biogenic sources that compare favorably to 

fossil energy in terms of greenhouse gas emissions. 

A dissenting opinion in Attachment E offers support for applying the IPCC approach, discussed above, 

to regulatory decisions about biogenic feedstocks. Such an approach would not be consistent with EPA’s 

responsibility under the Clean Air Act, nor would it capture the marginal effect of increased biomass 

harvesting on forest carbon stocks and atmospheric carbon levels. Specifically, EPA is not charged with 

regulating regional or national forest carbon stocks: it must regulate stationary facilities. The dissenting 

opinion expressed a preference for exempting bioenergy from greenhouse gas regulation so long as land 

carbon stocks are rising. However, the general consensus view of the SAB is that the IPCC inventories, 

a static snapshot of emissions at any given point in time, are a reporting convention that lacks 

connection to any associated policies or implementation. Merely knowing whether carbon sequestration 

at the landscape level has increased or decreased tells us nothing about the incremental effect that 

bioenergy production has on carbon emissions. The IPCC inventories do not explicitly link biogenic 

CO2 emission sources and sinks to stationary sources, nor do they provide a mechanism for measuring 

changes in emissions as a result of changes in the building and operation of stationary sources using 

biomass.

Issues with Biogenic Accounting Factor (BAF) Calculation 

The Framework presents an alternative to a categorical inclusion or exclusion by offering an equation 

for calculating a Biogenic Accounting Factor (BAF) that would be used to adjust the onsite biogenic 

emissions at the stationary source emitting biogenic CO2 on the basis of information about growth of the 

feedstock and/or avoidance of biogenic emissions and more generally the carbon cycle. Note that in the 

comments below, the SAB’s advice on the Framework (i.e., the application of the BAF equation to 

biogenic feedstocks) differs by feedstock category. In particular, the SAB is more critical of the 

Framework’s treatment of biomass from roundwood trees than from agricultural and waste feedstocks. 

Agricultural and Waste Feedstocks

For faster growing biomass like agricultural crops, the anticipated future baseline approach is 

still necessary to reflect changes in dynamic processes, e.g., soil carbon, “anyway” emissions 

(those that would occur anyway without removal or diversion of nongrowing feedstocks, for 

example, corn stover) , and landscape changes. For agricultural feedstocks in general, the 

Framework captures many of the factors necessary for estimating the offsite carbon change 

associated with use of short rotation (agricultural) feedstocks. These include factors to represent 

the carbon embodied in products leaving a stationary source, the proportion of feedstock lost in 

conveyance, the offset represented by sequestration, the site-level difference in net carbon flux as 

a result of harvesting, “anyway” emissions and other variables. In addition to the anticipated 

baseline, a noticeable omission is the absence of consideration of nitrous oxide (N2O) emissions 

from fertilizer use, potentially a major onsite greenhouse gas loss that could be induced by a 

growing bioenergy market. 
5

For short rotation feedstocks where carbon accumulation and “anyway” emissions are within one 

to a few years (i.e., agricultural residues, perennial herbaceous crops, mill wood wastes, other 

wastes), the Framework may, with some adjustments to address estimation problems (including 

an anticipated baseline for soil carbon changes, residue disposition and land management) and 

careful consideration of data and implementation, accurately represent direct carbon changes in a 

particular region. For logging residues and other feedstocks that decay over longer periods, 

decomposition cannot be assumed to be instantaneous and the Framework could be modified to 

incorporate the time path of decay of these residues if they are not used for bioenergy. This time 

path should consider the alternative fate of these residues, which in some cases may involve 

removal and burning to reduce risks of fire or maintain forest health. 

For waste materials (municipal solid waste), the Framework should consider the alternate 

disposition of waste material (what would happen if not used as feedstock) in an anticipated 

baseline (counterfactual) framework. This anticipated baseline should include emissions and 

partial capture of methane (CH4) emissions from landfills. In general, when accounting for 

emissions from wood mill waste and pulping liquor, the EPA should recognize these emissions 

are part of a larger system that includes forests, solid wood mills, pulp mills and stationary 

energy sources. Accounting for greenhouse gases in the larger system should track all emissions 

or forest stock changes over time across the outputs from the system so as to account for all 

fluxes. Within the larger system, the allocation of fluxes to wood/paper products or to a 

stationary source is a policy decision. The agency should consider how its Framework meets the 

scientific requirement to account (allocate) all emissions across the larger system of forests, mills 

and stationary sources over time.

Forest-Derived Woody Biomass

The EPA’s stated objective was to accurately reflect the carbon outcome of biomass use by 

stationary sources. For forest-derived woody biomass, the Framework did not achieve this 

objective. To calculate BAF for biomass from roundwood trees, the agency proposed the concept 

of regional carbon stocks (with the regions unspecified) and posed a “rule” whereby any 

bioenergy usage that takes place in a region where carbon stocks are increasing would be 

assigned a BAF of 0 (and hence carbon emissions would not be subject to greenhouse gas 

regulation). This decouples the BAF from a particular facility’s biogenic emissions and the 

sequestration (offset) associated with its particular feedstock. Emissions from a stationary facility 

would be included or excluded from greenhouse gas regulation depending on a host of factors in 

the region far beyond the facility’s control. 

To accurately capture the carbon outcome, an anticipated baseline approach and landscape level 

perspective are needed. An anticipated baseline requires selecting a time period and determining 

what would have happened anyway without the harvesting and comparing that impact with the 

carbon trajectory associated with harvesting of biomass for bioenergy. Although any “business 

as usual” projection would be uncertain, it is the only means by which to gauge the incremental 

impact of woody biomass harvesting. The Framework discusses this anticipated future baseline 

approach but does not attempt it. Instead a fixed reference point and an assumption of geographic 

regions were chosen to determine the baseline for whether biomass harvesting for bioenergy 

facilities is having a negative impact on the carbon cycle. The choice of a fixed reference point 

may be the simplest to execute, but it does not properly address the additionality question, i.e., 
6

the extent to which forest stocks would have been growing or declining over time in the absence 

of bioenergy. The agency’s use of a fixed reference point baseline coupled with a division of the 

country into regions implies that forest biomass emissions could be granted an exemption simply 

because the location of a stationary facility is in an area where forest stocks are increasing. The 

reference point estimate of regionwide net emissions or net sequestration does not indicate, or 

estimate, the difference in greenhouse gas emissions (the actual carbon gains and losses) over 

time that stem from biomass use. As a result, the Framework fails to capture the causal 

connection between forest biomass growth and harvesting and atmospheric impacts and thus may 

incorrectly assess net CO2 emissions of a facility’s use of a biogenic feedstock. 

A landscape, versus stand or plot, perspective is important because land-management decisions 

are simultaneous, e.g., harvesting, planting, silvacultural treatments. Thus, there are concurrent 

carbon stock gains and losses that together define the net implications over time. A landscape 

level analysis, and BAF calculation, will capture these. 

Leakage 

Leakage is a phenomenon by which efforts to reduce emissions in one place affect market prices 

that shift emissions to another location or sector. “Bad” leakage (called “positive” leakage in the 

literature) occurs when the use of biogenic feedstocks causes price changes which, in turn, drive 

changes in consumption and production outside the boundary of the stationary source, even 

globally, that lead to increased carbon emissions. One type of positive leakage could occur if 

land is diverted from food/feed production to bioenergy production which increases the price of 

conventional agricultural and forest products in world markets and leads to conversion of carbon 

-rich lands to crop production and the release of carbon stored in soils and vegetation. The use of 

biogenic feedstocks can also affect the price of fossil fuels by lowering demand for them and 

thereby increasing their consumption elsewhere. “Good” leakage (called “negative” leakage in 

the literature) could occur if the use of biomass leads to carbon-offsetting activities elsewhere. 

The latter could arise for example, if increased demand for biomass and higher prices generate 

incentives for investment in forest management, beyond the level needed directly for bioenergy 

production, which increases net forest carbon sequestration. The assessment of the overall 

magnitude of leakage, associated with the use of bioenergy for fuel is highly uncertain and 

differs considerably across studies and within a study, depending on underlying assumptions. It 

will also differ by feedstock and location. The Framework’s equation for BAF includes a term 

for leakage, however the agency did not specify an approach to calculate the value for leakage.

In dealing with leakage, we suggest measuring the magnitude of leakage to the extent possible or 

at least examining the directionality of net leakage – whether it is positive (leading to increased 

carbon emissions elsewhere) or negative (leading to carbon offsetting activities). In some cases 

even net directionality may be hard to establish. This information can be used to develop 

supplementary policies to control leakage before it occurs. We do not recommend incorporating 

a measure of leakage in the estimate of BAF which would effectively hold a stationary facility 

responsible for emissions that are outside its control and occurring due to market effects. There is 

no literature in the social sciences to show that this is an effective way to control emissions. 

Moreover, when this is coupled with the uncertainties inherent in measuring it in the first place 

the net benefits of doing this are even more unclear. Supplementary policies that restrict the 

types of land and management practices that can be used to grow biomass for bioenergy and the 

types of feedstocks that can be used can reduce the leakage effects of bioenergy use. In addition, 
7

the agency should be alert to leakage that may occur in other media (e.g., fertilizer runoff into 

waterways) and the need for targeted policies to prevent or abate it. 

Implementation details

The EPA’s Framework was lacking in implementation details. Implementation is crucial and 

some of the agency’s current proposals will be difficult to implement. Data availability and 

quality, as well as procedural details (e.g., application process, calculation frequency) are 

important considerations for assessing the feasibility of implementation and scientific accuracy 

of results.

Consistency with fossil fuel emissions accounting

For comparability, there should be consistency between fossil fuel and biogenic emissions 

accounting. Fossil fuel feedstock emissions accounting from stationary sources under the Clean 

Air Act are not adjusted for offsite greenhouse gas emissions and carbon stock changes. Unlike 

fossil fuels, however, biogenic feedstocks have carbon sequestration that occurs within a relevant 

timeframe. While EPA’s primary goal is to account for this offsetting sequestration, its biogenic 

emissions accounting should be consistent with emissions accounting for fossil fuels for other 

emissions accounting categories—including losses, international leakage, and fossil fuel use 

during feedstock extraction, production and transport. Including some accounting elements for 

biomass and not for fossil fuels would be a policy decision without the underlying science to 

support it.

Case Studies 

The case studies provided in EPA’s Framework were useful for informing the reader with examples of 

how the Framework would be applied but they did not fully cover the relevant variation in feedstocks, 

facilities, regions and land uses that would be required to more fully evaluate the Framework. 

Additional case studies for landfills and waste combustion, dedicated energy crops like switchgrass and 

a variety of waste feedstocks would have been useful to see the implementation of the Framework. 

Case studies on different cropping systems with different land and soil types, internal reuse of process 

materials (e.g., black liquor in pulp and paper mills) and municipal solid waste would have greatly aided 

the SAB’s evaluation of the Framework. 

Recommendations for Revising BAF 

The SAB was asked for advice regarding potential revisions to the Framework. We recognize the 

agency faces daunting technical challenges if it wishes to implement the Framework’s facility-specific 

BAF approach. If the EPA decides to retain and revise a facility-specific Framework, the SAB 

recommends consideration of the following improvements. 

Develop a separate BAF equation for each feedstock category as broadly categorized by type, 

region, prior land use and current management practices. Feedstocks could be categorized into 

short rotation dedicated energy crops, crop residues, forest residues, municipal solid waste, 

trees/forests with short accumulation times, trees/forests with long accumulation times and 

agricultural residue, wood mill residue and pulping liquor. 

o For long-accumulation feedstocks like roundwood, use an anticipated baseline approach to 

compare emissions from increased biomass harvesting against a baseline without increased 
8

biomass demand. For long rotation woody biomass, sophisticated modeling is needed to 

capture the complex interaction between electricity generating facilities and forest markets 

and landscape level effects, in particular: market driven shifts in planting, management and 

harvests; induced displacement of existing users of biomass; land use changes, including 

interactions between agriculture and forests; and the relative contribution of different 

feedstock source categories (logging residuals, pulpwood or roundwood harvest).

o For residues, consider alternate fates (e.g., some forest residues may be burned if not used for 

bioenergy) and information about decay. An appropriate analysis using decay functions 

would yield information on the storage of ecosystem carbon in forest residues. 

o For materials diverted from the waste stream, consider their alternate fate, whether they 

might decompose over a long period of time, whether they would be deposited in anaerobic 

landfills, whether they are diverted from recycling and reuse, etc. For feedstocks that are 

found to have relatively minor impacts, the agency may need to weigh ease of 

implementation against scientific accuracy. After calculating decay rates and considering 

alternate fates, including avoided methane emissions, the agency may wish to declare certain 

categories of feedstocks with relatively low impacts as having a very low BAF, or setting 

BAFs equal to 0 or possibly negative values in the case where methane emissions are 

avoided.

o For short rotation energy crops grown specifically for bioenergy, the anticipated baseline 

approach should be used to determine soil carbon sequestration. The BAF for such 

feedstocks could be negative since they have considerable potential to sequester carbon in 

soils and roots. 

Incorporate various time scales and consider the tradeoffs in choosing between different time 

scales when estimating the BAF. 

For all feedstocks, develop supplementary policies to reduce carbon leakage based on at least an 

assessment of the directionality of leakage. 

Consider Default BAFs 

The SAB was not asked to recommend an approach that was outside the Framework, however, given the 

conceptual and scientific deficiencies of the Framework described above, and the prospective 

difficulties with implementation, the SAB recommends consideration of default BAFs by feedstock 

category and region. Under EPA’s current Framework, facilities would use individual BAFs designed to 

capture the incremental carbon cycle and net emissions effects of their use of a biogenic feedstock. 

Rather than trying to calculate a BAF at the facility-level, the SAB recommends that EPA consider 

calculating a default BAF for each feedstock category. With default BAFs by feedstock category, 

facilities would use a weighted combination of default BAFs based on their particular bundle of 

feedstocks. The defaults could rely on readily available data and reflect landscape and aggregate demand 

effects, including previous land use. Default BAFs might also vary by region and current land 

management practices due to differences these might cause in the interaction between feedstock 

production and the carbon cycle. The defaults would also have administrative advantages in that they 

would be easier to implement and update. Default BAFs for each category of feedstocks would 

differentiate among feedstocks using general information on their role in the carbon cycle. An 

anticipated baseline would allow for consideration of prior land use, management, alternate fate (what 

would happen to the feedstock if not combusted for energy) and regional differences. They would be 
9

applied by stationary facilities to determine their quantity of biogenic emissions that would be subject to 

the EPA’s greenhouse gas regulations. Facilities could also be given the option of demonstrating a lower 

BAF for the feedstock they are using. This would be facilitated by making the BAF calculation 

transparent and based on data readily available to facilities. Properly designed, a default BAF approach 

could provide incentives to facilities to choose feedstocks with the lower greenhouse gas impacts. 

The SAB also explored certification systems as a possible way to obviate the need to quantify a specific 

net change in greenhouse gases associated with a particular stationary facility. Carbon accounting 

registries have been developed to account for and certify CO2 emissions reductions and sequestration 

from changes in forest management. Theoretically, for the EPA’s purposes, a certification system could 

be tailored to account for emissions of a stationary facility after a comprehensive evaluation. Ultimately, 

the SAB concluded that it could not recommend certification without further evaluation because such 

systems could also encounter many of the same data, scientific and implementation problems that 

bedevil the Framework. 

Conclusion

Given the need to address the pressing realities of climate change, biomass resources are receiving much 

greater attention as a potential energy source. According to the U.S. Department of Energy, the U.S. has 

the capacity to produce a billion dry tons of biomass resources annually for energy uses (U.S. 

Department of Energy, 2011). As these materials play a greater role in the nation’s energy future, it will 

be increasingly important to have scientifically sound methods to account for greenhouse gas emissions 

from bioenergy. However, its greenhouse gas implications are more complex and subtle than the 

greenhouse gas impacts of fossil fuels. Unlike fossil fuels, forests and other biological feedstocks can 

grow back and sequester CO2 from the atmosphere. Given the complicated role that bioenergy plays in 

the carbon cycle, the Framework was written to provide a structure to account for net CO2 emissions. 

The Framework is a step forward in considering biogenic carbon emissions. 

The focus of the Framework is on point source emissions from stationary facilities with the goal of 

accounting for any offsetting carbon sequestration that may be attributed to the facility’s use of a 

biogenic feedstock. To create an accounting structure, the agency drew boundaries narrowly in 

accordance with its regulatory domain. These narrow regulatory boundaries are intended to account for 

biogenic carbon uptake and release associated with biomass that is combusted for energy purposes. As 

such, this Framework does not consider, nor is it intended to consider, all greenhouse gas emissions 

associated with the production and use of biomass energy. Ideally, comprehensive accounting for both 

biogenic and fossil fuels would extend through time and space to estimate the long-term impacts on net 

greenhouse gas emissions but the agency was constrained by its regulatory authority. To fully estimate 

net impact that can be attributed to bioenergy, the EPA would need to calculate the net change in global 

emissions over time resulting from increased use of biomass feedstocks as compared to a future without 

increased use of biogenic feedstocks. To capture this difference, the boundaries of analysis would need 

to include all factors in the life cycle of the feedstock and its products although computing global

emissions changes for individual facilities has its own daunting challenges. 

The boundaries imposed by the EPA’s regulatory authority necessarily restrict its policy choices, 

however economic research has shown that the most cost-effective way to reduce greenhouse gas 

emissions (or any other pollution) is to regulate or tax across all sources until they face equal marginal 

costs. Given the agency’s authority under the Clean Air Act, the most cost-effective economy-wide 

solution is not within its menu of choices. The agency’s regulation of stationary sources does not include 
10

other users of biomass (e.g., consumers of ethanol) that also have impacts on the carbon cycle as well as 

downstream consumers of products produced by these facilities. Note that EPA can only regulate endof-stack emissions and thus has to design a system that fits within its regulatory authority. 

The agency has taken on a difficult but worthy task and forced important questions. Practical 

considerations will, no doubt, weigh heavily in the agency’s decisions. In fact, any method that might be 

adopted or considered, including methods proposed by the SAB, should be subject to an evaluation of 

the costs of compliance and the carbon emissions savings likely to be achieved as compared to both a 

categorical inclusion and a categorical exclusion. Uncertainties in the assessment of both the costs and 

the emissions savings should be analyzed and used to inform the choice of policy. The U.S. Department 

of Agriculture (USDA) also is developing in parallel an accounting approach for forestry and 

agricultural landowners. It would be beneficial if the EPA and USDA approaches could be harmonized 

to avoid conflicts and take advantage of opportunities for synergy. In this Advisory, the SAB offers 

suggestions for how to improve the Framework while encouraging the agency to think about options 

outside its current policy menu. While the task of accounting for biogenic carbon emissions defies easy 

solutions, it is important to assess the strengths and limitations of each option so that a more accurate 

carbon footprint can be ascribed to the various forms of bioenergy. 
11

2. INTRODUCTION

Greenhouse gas emissions from the largest stationary sources became subject to regulation under the 

Prevention of Significant Deterioration (PSD) and Title V Operating Permit Programs of the Clean Air 

Act in January 2011. To target these regulations, EPA enumerated specific conditions under which these 

Clean Air Act permitting requirements would apply. Initially, only sources currently subject to the PSD 

permitting program or Title V (i.e., those that are newly-constructed or modified in a way that 

significantly increases emissions of a pollutant other than greenhouse gases) would be subject to 

permitting requirements for their greenhouse gas emissions. For these projects, only greenhouse gas 

emission increases of 75,000 tons per year (tpy) or more, on a carbon dioxide equivalent (CO2e) basis, 

would be subject to technology requirements under the PSD program. As of July 1, 2011, more facilities 

became subject to regulation based on their greenhouse gas emissions. Specifically, new and existing 

stationary sources (that are not already covered by the PSD or Title V programs) that emit greenhouse 

gas emissions of at least 100,000 tpy are subject to greenhouse gas regulation even if they do not exceed 

the permitting thresholds for any other pollutant. For these facilities, the PSD and Title V requirements 

would be triggered. The PSD program imposes "best available control technology" requirements to 

control greenhouse gas emissions. Title V generally does not impose technology requirements but rather 

requires covered facilities to report an overall compliance plan for meeting the requirements of the 

Clean Air Act. 

EPA’s staged-approach to regulating greenhouse gases from stationary sources sought to focus on the 

nation’s largest greenhouse gas emitters and hence “tailored” the requirements of these Clean Air Act 

permitting programs to cover power plants, refineries, and cement production facilities that meet certain 

conditions while exempting smaller sources like farms, restaurants, schools and other facilities. The 

question before the agency, and hence, the motivation for this SAB review, is whether and how to 

consider biogenic greenhouse gas emissions in determining whether facilities meet certain thresholds (as 

defined above) for Clean Air Act permitting. Biogenic CO2 emissions from bioenergy are generated 

during the combustion or decomposition of biologically based material. 

It is in this context that the EPA Office of Air and Radiation requested the EPA’s Science Advisory 

Board (SAB) to review and comment on its Accounting Framework for Biogenic CO2 Emissions from 

Stationary Sources (Framework, September 2011). The Framework considers the scientific and 

technical issues associated with accounting for emissions of biogenic carbon dioxide (CO2) from 

stationary sources and develops a framework to adjust the stack emissions from stationary sources using 

bioenergy based on the induced changes in carbon stocks on land (in soils, plants and forests). Because 

of the unique role of biogenic feedstocks in the overall carbon cycle, EPA deferred for a period of three 

years the application of permitting requirements to biogenic CO2 emissions from bioenergy and other 

biogenic stationary sources. In its deferral, EPA committed to conduct a detailed examination of the 

science and technical issues associated with biogenic CO2 emissions and submit its study for review by 

the Science Advisory Board. To conduct the review, the SAB Staff Office formed the Biogenic Carbon 

Emissions Panel with experts in forestry, agriculture, greenhouse gas measurement and inventories, land 

use economics, ecology, climate change and engineering. 

The SAB was asked to review and comment on (1) the agency's characterization of the science and 

technical issues relevant to accounting for biogenic CO2 emissions from stationary sources; (2) the 

agency's framework, overall approach, and methodological choices for accounting for these emissions; 
12

and (3) options for improving upon the framework for accounting for biogenic CO2 emissions (See 

Appendix A: Charge to the SAB Panel). 

The Biogenic Carbon Emissions Panel held a face-to-face meeting on October 25 – 27, 2011, and 

teleconferences on January 27, 2012, March 20, 2012, May 23, 2012 and May 26, 2012. The Panel’s 

draft report was reviewed by the chartered SAB on August 31, 2012. During the course of deliberations, 

the SAB Panel reviewed background materials provided by the Office of Air and Radiation and 

considered written and oral comments from members of the public.
13

3. RESPONSES TO EPA’s CHARGE QUESTIONS

3.1. The Science of Biogenic CO2 Emissions

Charge Question 1: In reviewing the scientific literature on biogenic CO2 emissions, EPA 

assessed the underlying science of the carbon cycle, characterized fossil and biogenic carbon 

reservoirs, and discussed the implications for biogenic CO2 accounting.

Does the SAB support EPA’s assessment and characterization of the underlying science and the 

implications for biogenic CO2 accounting?

EPA has done an admirable job of reviewing the science behind the carbon cycle and greenhouse gas 

emissions and their relationship to climate change, extracting some of the critical points that are needed 

to create the proposed Framework. Figure 2-1 in the Framework captures the global carbon cycle 

showing the flows and pools of carbon. The chapter goes on to describe the task of quantifying the 

impact of transforming biologically based carbon from a terrestrial storage pool (such as aboveground 

biomass) into CO2 via combustion, decomposition or processing at a stationary source. At the same 

time, there are several important scientific issues that are not addressed in the Framework, as well as 

scientific issues that are briefly discussed but not sufficiently explored in terms of how they relate to the 

Framework. In the following section, the SAB describes a series of deficiencies with the EPA 

characterization of the science behind biogenic CO2 accounting and suggests some areas where the 

science could be strengthened. 

Time scale

One fundamental deficiency in the EPA report is the lack of discussion of the different time scales 

inherent in the carbon cycle and the climate system that are critical for establishing an accounting 

system. This is a complicated subject because there are many different time scales that are important for 

the issues associated with biogenic carbon emissions. At the global scale, there are multiple time scales 

associated with mixing of carbon throughout the different reservoirs on the Earth’s surface. When 

carbon dioxide is released into the air from burning fossil fuels, roughly 45% stays in the air over the

course of the following year. Of the 55% that is removed, roughly half is taken up by the ocean, mostly 

in the form of bicarbonate ion, and the other half is taken up by the terrestrial biosphere, primarily 

through reforestation and enhanced photosynthesis. The airborne fraction (defined as the fraction of 

emissions that remains in the air) has been remarkably constant over the last two decades. 

There is considerable uncertainty over how the magnitude of ocean and terrestrial uptake will change as 

the climate warms during this century. If the entire ocean were to instantly reach chemical equilibrium 

with the atmosphere, the airborne fraction would be reduced to 20 to 40% of cumulative emissions, with 

a higher fraction remaining in scenarios with higher cumulative emissions. In other words, the ocean 

chemical system by itself cannot remove all the CO2 released in the atmosphere. Because carbon uptake 

by the ocean is limited by the rate of mixing between the shallow and deeper waters, this complete 

equilibration is expected to take thousands of years. Over this century, if global CO2 emissions continue 

to rise, most models predict that ocean uptake will stabilize between 3 to 5 gigatons per year (GtC/y), 

implying that the fraction of emissions taken up by the ocean will decrease. For the terrestrial biosphere, 

there is a much wider envelope of uncertainty; some models predict that CO2 uptake will continue to 

keep pace with the growth in emissions, while other models suggest that CO2 uptake will decline, even 
14

becoming a net source of CO2 to the atmosphere if processes such as release of carbon from the tundra 

or aridification of the tropics were to occur. 

Over the time scale of several thousand years, once ocean equilibration is complete and only 20 to 40% 

of cumulative emissions remains in the atmosphere, dissolution of carbonate rocks on land and on the 

ocean floor will further reduce the airborne fraction to 10 to 25% over several thousand years to ten 

thousand years. Excess anthropogenic CO2 emissions will stay in the atmosphere for more than 100,000 

years, slowly drawn down by silicate weathering that converts the CO2 to calcium carbonate, as well as 

slow burial of organic carbon on the ocean floor. The size of this “tail” of anthropogenic CO2 depends 

on the cumulative emissions of CO2, with higher cumulative emissions resulting in a higher fraction 

remaining in the atmosphere.

Another important time scale for considering accounting systems for biogenic carbon emissions is the 

period over which the climate responds to carbon dioxide and other greenhouse gases. The importance 

of the timing of emissions depends on whether one uses a global warming limit or a cumulative 

emissions limit. Some modeling exercises have shown that the probability of limiting warming to 2 °C 

or below in the twenty-first century is dependent upon cumulative emissions by 2050 (Meinshausen et 

al. 2009). This suggests that an early phase of elevated emissions from forest biomass could reduce the 

odds of limiting climate warming if warming is limited to 2 °C. Another climate modeling study has

demonstrated that peak warming in response to greenhouse gas emissions is primarily sensitive to 

cumulative greenhouse gas emissions over a period of roughly 100 years, and, so long as cumulative 

emissions are held constant, is relatively insensitive to the emissions pathway within that time frame

(Allen et al. 2009). What this means is that an intervention in forests or farming that results in either an 

increase or decrease in storage of carbon or emissions reductions must endure longer than 100 years to 

have an influence on the peak climate response as long as cumulative emissions from all sources are 

constant. Conversely, if these changes last less than 100 years, harvesting of biomass for bioenergy 

resulting in release of carbon dioxide will have a relatively small effect on peak warming. While the 

harvesting of trees for bioenergy can result in a carbon debt even at the landscape level (Mitchell et al. 

2012), this may not reflect potential climate benefits at longer time scales if biomass is regrown 

repeatedly and substituted for coal over successive harvest cycles (Galik and Abt 2012). 

Time scales are also important for individual feedstocks and their regeneration at a more local scale. 

Given that the EPA’s objective is to account for the atmospheric impact of biogenic emissions, it is 

important to consider the turnover times of different biogenic feedstocks in justifying how they are 

incorporated into the Framework. The fundamental differences in stocks and their turnover times as they 

relate to impacts on the atmosphere are not well discussed or linked. If a carbon stock is cycling quickly 

on land and regrowth is sufficient to compensate for carbon losses from harvesting, it may have a 

beneficial impact when it displaces fossil fuel over successive cycles of growth and harvest (assuming 

this temporal displacement exceeds 100 years). If the carbon stock, or some part of it, turns over more 

slowly, if regrowth is not assured or if feedstocks are not being used to continuously displace fossil 

fuels, the impact on climate worsens.

There is a continuum of carbon stock size and turnover among the biogenic feedstock sources included 

in the Framework, but there is little background discussion of the variation in stock and turnover and 

how that informs the accounting method. The Framework sets up categories of feedstocks based on their 

source, but these groupings do not translate into differential treatment in the Framework. In Table 1, the 

SAB offers a rudimentary framework for thinking about climate impacts over time for various feedstock 

groups. The direct climate impact refers to the effect of growing and harvesting the feedstock on the 
15

land based carbon stocks. The indirect/leakage effect refers to the effect on carbon emissions that arises 

because the production of bioenergy competes for land with conventional crops and raises crop prices 

which, in turn, can lead to changes in land uses like deforestation. Price signals can also lead to 

cropland expansion in other locations, thus releasing carbon stocks from soil and vegetation. The 

column labeled “leakage” is explained further in Section 3.3 where the SAB offers some comments on 

the treatment of “leakage” or the phenomena by which efforts to reduce emissions in one place affect 

market prices that shift emissions to another location or sector. As shown in Table 1, the time scale 

matters most for long rotation trees where term refers to the length of rotation of trees. In the case of 

forest residues, “near term” is the length of time it would take for residue to decompose if left in the 

forest.

Table 1. Temporal Carbon Effects of Feedstock Groups

Feedstock Direct Climate Impact Indirect/Leakage 

Impact

Comments

Near 

Term

Long

Term

Agricultural 

Residues

+/ 0

-

+/0

-

None Could be zero if stover removal 

rates are low. Also depends on 

nitrogen application rates.

Negative if carbon remains 

sequestered in ash/biochar or if 

accompanied by carbon capture 

and storage. 

Forest 

Residues

+

-

0

-

None Depends on the rate constant of 

loss, and the interval of residue 

or slash creation and the 

alternative use of the residue

Negative if carbon remains 

sequestered in ash/biochar or if 

accompanied by carbon capture 

and storage.

Energy 

Crops/Short 

Rotation 

Woody Crops

- - Small if grown 

on idle land 

/noncropland,

positive in the 

short run 

otherwise

negative in the 

long run

Depends on the extent of soil 

carbon sequestration which may 

be substantial in the short and 

medium term but reach a plateau 

in the long term. Also depends 

on land use history, land 

management practices

Long 

Rotation 

Trees

+ - Could be 

negative or 

positive in the 

short run; 

negative in the 

long run

Depends on harvest rotation and 

regrowth rates
16

Negative sign (-) indicates a reduction in greenhouse gas emissions in the atmosphere and/or increase in carbon stocks. 

Positive (+) sign refers to an increase in greenhouse gas emissions in the atmosphere or a reduction in soil carbon 

stocks. 

Appendix B discusses a set of studies by Cherubini and co-authors (Cherubini et al. 2011, 2012) that

provide examples for estimating the temporal distribution of atmospheric impacts from biomass 

harvesting by framing the analysis in terms of global warming potentials (GWPs) and global 

temperature potentials (GTPs) for harvested biomass. Figure B-1 in Appendix B, adapted from 

Cherubini et al. (2012), depicts mean surface temperature changes for a simple contrived comparison of 

biogenic emissions from a single forest stand over hundreds of years as compared to comparable fossil 

emissions. While much is assumed regarding global activity (emissions, landscape responses, 

investment behavior), Figure B-1 demonstrates the importance of the time horizon and the weight to 

place on temperature increases that occur in the short term versus temperature increases that occur later. 

As shown in Figure B-1, a 50-year time horizon (or less) would obscure the longer-term climate 

consequences of bioenergy. The Global Temperature Potential of Biomass, denoted as GTPbio, would 

continue to decline for time horizons beyond 100 years since there is no net temperature increase after 

100 years. The choice of weighting of temperature effects at different time horizons could be influenced 

by the estimated damages associated with the temperature increases as well as the social rate of time 

preference for avoiding damages. The discussion by Kirschbaum (2003, 2006) of the impact of 

temporary carbon storage (the inverse of temporary carbon release from biomass harvesting for 

bioenergy) points out that the exact climate impact of temporary CO2 storage (or emissions) depends on 

the type of impact, as some depend on peak temperature, whereas others, such as melting of polar ice 

sheets, depend more on time-averaged global temperature. There is no scientifically correct answer 

when choosing a time horizon, although the Framework should be clear about what time horizon it uses, 

and what that choice means in terms of valuing long term versus shorter term climate impacts.

Disturbance

Because ecosystems respond in complicated ways to disturbances (e.g., harvesting, fire) over long 

periods of time, and with a high degree of spatial heterogeneity, the state of knowledge about 

disturbance and impacts on carbon stocks and turnover should be reviewed within the context of 

relevant time scales and spatial extents. This is highly relevant to producing accurate estimates of 

biogenic emissions from the land. There is also insufficient treatment given to the existing literature on 

the impact of different land management strategies on soil carbon, which is important for understanding 

how carbon stocks may change over many decades. 

Non-CO2 Greenhouse Gases

The Framework does not incorporate greenhouse gases other than CO2. Ideally both fossil fuels and 

biogenic fuels should be subject to the same emissions accounting to fully capture the difference 

between the two types of fuels in terms of their greenhouse gas emissions. For biogenic feedstocks, the 

most important source of non-CO2 emissions is likely to be N2O produced by the application of fertilizer

(Crutzen et al. 2007). In particular, if the biomass feedstock is from an energy crop that results in 

different N2O emissions vis-a-vis other crops, should this be counted? Is it negligible? This issue is not 

introduced in the science section. N2O is relatively long-lived (unlike methane) and therefore the climate 

impacts of heavily fertilized biomass (whether in forests or farms) are greater than non-fertilized 

biomass. There is a substantial literature on N2O from fertilizer use that was not discussed in the 

Framework. If the decision to not count non-CO2 greenhouse gases stems from a need to render the 

carbon accounting for biogenic sources parallel with fossil fuels, this needs to be explicitly discussed. 
17

3.2. Biogenic CO2 Accounting Approaches

Charge Question 2: In this report, EPA considered existing accounting approaches in terms of 

their ability to reflect the underlying science of the carbon cycle and also evaluated these 

approaches on whether or not they could be readily and rigorously applied in a stationary source 

context in which onsite emissions are the primary focus. On the basis of these considerations, 

EPA concluded that a new accounting framework is needed for stationary sources. 

2(a). Does the SAB agree with EPA’s concerns about applying the IPCC national approach to 

biogenic CO2 emissions at individual stationary sources?

The SAB concurs with EPA’s rejection of the application of the Intergovernmental Panel on Climate 

Change (IPCC) national accounting approach to biogenic carbon emissions at individual stationary 

sources. The IPCC develops guidelines for countries to report their anthropogenic greenhouse gas 

emissions. These emissions are reported as aggregate numbers by sectors, e.g., the Land-Use change 

and Forestry Sector, the Energy Sector, Industrial Processes and Product Use, etc. The IPCC’s inventory 

of global greenhouse emissions (i.e., all emissions are counted) is comprehensive in quantifying all 

emissions sources and sinks, but does not describe linkages among supply chains. In other words, it is 

essentially a “production-based inventory” or “geographic inventory” rather than a “consumption-based 

inventory” (Stanton et al. 2011). The IPCC inventory offers a static snapshot of emissions at any given 

time, but it does not expressly show changes in emissions over time. 

A dissenting opinion presented by Dr. Roger Sedjo in Appendix E expresses a preference to exclude 

bioenergy from greenhouse gas regulation so long as aggregate national forest carbon stocks are rising 

relative to a fixed point baseline. The SAB notes that such an approach would not be consistent with 

EPA’s responsibility under the Clean Air Act as it would not capture the marginal effect of increased 

biomass harvesting on forest carbon stocks and atmospheric carbon levels. Specifically, EPA is not 

charged with regulating regional or national forest carbon stocks: it must regulate stationary facilities. 

As such, the IPCC inventories, a static snapshot of emissions at any given point in time, are a reporting 

convention that has no associated connections to policies or implementation. These inventories do not 

explicitly link biogenic CO2 emission sources and sinks to stationary sources, nor do they provide a 

mechanism for measuring changes in emissions as a result of changes in the building and operation of 

stationary sources using biomass.

2(b). Does the SAB support the conclusion that the categorical approaches (inclusion and 

exclusion) are inappropriate for this purpose, based on the characteristics of the carbon cycle?

A decision about a categorical inclusion or exclusion will likely involve many considerations that fall 

outside the SAB’s scientific purview, such as legality, feasibility and, possibly, political will. The SAB 

cannot speak to the legal or full implementation difficulties that could accompany any policy on 

biogenic carbon emissions but some scientific observations that may inform the Administrator’s policy 

decision are offered below. 

The notion that biomass is carbon neutral arises from the fact that the carbon released as CO2 upon 

combustion was previously removed from the atmosphere as CO2 during plant growth. While it is true 

that emissions from burning a single tree will equal the same amount of carbon sequestered by that tree 
18

at a micro level, at a macro level, net emissions will depend upon rates of harvest vis-a-vis rates of 

sequestration over time. Thus, the physical flow of carbon in the biomass combusted for bioenergy 

represents a closed loop that passes through a stationary source. Under an accounting framework where 

life cycle emissions associated with the production and use of biomass are attributed to a stationary 

source, assuming carbon neutrality of biomass implies that the net sum of carbon emissions from all 

sources and sinks is zero, including all supply chain and market-mediated effects. Carbon neutrality 

cannot be assumed for all biomass energy a priori (Rabl et al. 2007; Johnson 2009; Searchinger et al. 

2009). There are circumstances in which biomass is grown, harvested and combusted in a carbon neutral 

fashion but carbon neutrality is not an appropriate a priori assumption; it is a conclusion that should be 

reached only after considering a particular feedstock production and consumption cycle. There is 

considerable heterogeneity in feedstock types, sources, production methods and leakage effects; thus net 

biogenic carbon emissions will vary considerably. 

Given that some biomass combustion could have positive net emissions, a categorical exclusion would

remove any responsibility on the stationary source for CO2 emissions from its use of biogenic material 

from the entire system (i.e., the global economy) and provide no incentive for the development and use 

of best management practices. Conversely, a categorical inclusion would provide no incentive for using 

biogenic sources that compare favorably to fossil energy in terms of greenhouse gas emissions. 

The commentary above merely reflects some scientific considerations. The SAB recognizes that, in 

reality, the EPA may face difficult tradeoffs between ease of implementation and other goals (e.g., 

maximizing scientific accuracy by modeling the decomposition of logging residues). While an 

alternative approach of default Biogenic Accounting Factors (BAFs) is offered for the agency’s 

consideration (see Section 4), the SAB cannot advise the agency on the legal feasibility of any approach. 

2(c). Does the SAB support EPA's conclusion that a new framework is needed for situations in 

which only onsite emissions are considered for non-biologically-based (i.e., fossil) feedstocks?

Through discussions with the Panel at the public meeting, the EPA agreed that this question is redundant 

with other charge questions and therefore does not require a separate response.

2(d). Are there additional accounting approaches that could be applied in the context of biogenic 

CO2 emissions from stationary sources that should have been evaluated but were not?

Several other agencies are developing methods for assessing greenhouse gas emissions by facilities. 

These methods could inform the approach developed by the EPA. The methods that are being developed 

include the DOE 1605(b) voluntary greenhouse gas registry targeted to entities, which has many similar 

characteristics to the approach proposed by EPA for stationary sources. There is also the Climate Action 

Registry developed in California that uses a regional approach to calculate baselines based on inventory 

data and may inform the delineation of geographic regions and choice of baselines in the EPA approach. 

USDA also is developing in parallel an accounting approach for forestry and agricultural landowners. It 

would be beneficial if the EPA and USDA approaches could be harmonized to avoid conflicts and take 

advantage of opportunities for synergy.
19

3.3. Methodological Issues

Charge Question 3: EPA identified and evaluated a series of factors in addition to direct biogenic 

CO2 emissions from a stationary source that may influence the changes in carbon stocks that 

occur offsite, beyond the stationary source (e.g., changes in carbon stocks, emissions due to landuse and land management change, temporal and spatial scales, feedstock categorization) that are 

related to the carbon cycle and should be considered when developing a framework to adjust total 

onsite emissions from a stationary source. 

3(a). Does SAB support EPA’s conclusions on how these factors should be included in accounting 

for biogenic CO2 emissions, taking into consideration recent advances and studies relevant to 

biogenic CO2 accounting?

The SAB’s response to this question differs by feedstock. On balance, the Framework includes many 

important factors but some factors suffer from significant estimation and implementation problems.

For agricultural feedstocks, the factors identified by EPA to adjust the CO2 emissions from a stationary 

source for direct off-site changes in carbon stocks are appropriate but suffer from significant estimation 

and implementation problems. The Framework includes factors to represent the carbon embodied in 

products leaving a stationary source, the proportion of feedstock lost in conveyance, the offset 

represented by sequestration, the site-level difference in net carbon flux as a result of harvesting, the 

emissions that would occur “anyway” from removal or diversion of non-growing feedstocks (e.g., corn 

stover) and other variables. In some cases, energy crops like miscanthus and switchgrass have 

significant potential to sequester carbon in the soil and be sinks for carbon rather than a source

(Anderson-Teixeira et al. 2009). In other cases, the production of bioenergy could result in by-products 

like biochar which sequester significant amounts of carbon. A large value of the Total Net Change in 

Site Emissions (SITE_TNC) and/or Sequestered Fraction (SEQP) variables in the accounting equation 

could result in a negative BAF for such feedstocks. The Framework should clarify how a negative BAF 

would be used and whether it could be used by a facility to offset fossil fuel emissions. Restricting BAF 

to be non-negative would reduce incentives to use feedstocks with a large sequestration potential.

For waste materials (municipal solid waste, manure, wastewater, construction debris, etc.), the 

Framework assigns a BAF equal to 0 for biogenic CO2 released from waste decay at waste management 

systems, waste combustion at waste incinerators or combustion of captured waste-derived CH4. The 

Framework further states that for any portion of materials entering a waste incinerator that is harvested 

for the purpose of energy production at that incinerator, biogenic CO2 emissions from that material 

would need to be accounted according to the Framework calculations. Municipal solid waste biomass is 

either disposed of in a landfill or combusted in facilities at which energy is recovered. Smaller amounts 

of certain waste components (food and yard waste) may be processed by anaerobic digestion and 

composting. The SAB concurs with the Framework that the CO2 released from the decomposition of 

biogenic waste in landfills, compost facilities or anaerobic digesters could reasonably be assigned a BAF 

of 0. In addition, given that methane (CH4) is a more potent greenhouse gas than CO2, the Framework

should account for CH4 emissions from landfills in cases where the methane is not captured. The SAB 

recognizes that EPA may address methane in other regulatory contexts. 
20

When accounting for emissions from waste sources including logging residue, wood mill waste and 

pulping liquor, the EPA should recognize that these emissions are part of a larger system that includes

co-products with commercial products. For logging residue, wood mill waste and pulping liquor the 

larger system includes forests, solid wood mills, pulp mills and stationary energy sources. Accounting 

for greenhouse gases in the larger system needs to track all biomass emissions or forest stock changes 

and needs to assure they are allocated over time across the outputs (product and co-products) from the 

system so as to account for all fluxes. Within the larger system, the allocation of fluxes to wood/paper 

products or to emissions from a stationary source can be supported by scientific reasoning but is 

ultimately a policy decision. The agency should consider how the Framework meets the scientific 

requirement to account for (allocate) all emissions to products and co-products across the larger system 

of forest, mills and stationary sources over time. 

For roundwood, the calculation of BAF would need to account for the time path of carbon accumulation 

and emissions from logging residue and apply a landscape perspective. The landscape perspective is 

important because of simultaneous management decisions that emit and sequester greenhouse gases 

concurrently and therefore define the net implications over time. The Framework recognizes some of the 

challenges associated with defining the spatial and temporal time scale and in choosing the appropriate 

baseline. Ultimately, however, the Framework chooses an approach that disregards any consideration of 

the time scales over which biogenic carbon stocks are accumulated or depleted and does not actually 

estimate carbon stock changes associated with biomass use. Instead the Framework attempts to 

substitute a spatial dimension for time and creates an accounting system that generates outcomes 

sensitive to the regional scale at which carbon emissions attributed to a stationary source are evaluated. 

Below are some comments on particular factors. 

Level of Atmospheric Reduction (LAR): The term refers to the proportional atmospheric carbon 

reduction from sequestration during feedstock regrowth (GROW) or avoided emissions (AVOIDEMIT) 

from the use of residues that would have been decomposed and released carbon emissions “anyway.” 

The scientific justification for constraining the range of LAR to be greater than 0 but less than 1 is not 

evident since it is possible for feedstock production to exceed feedstock consumption. These two terms 

are not applicable together for a particular feedstock and representing them as additive terms in the 

accounting equation can be confusing. Additionally, the value of LAR for forest biomass is sensitive to 

the size of the region for which growth is compared to harvest.

Loss (L): This term is included in the Framework to explicitly adjust the area needed to provide the total 

feedstock for the stationary facility. It is a term used to include the emissions generated by the feedstock 

lost during storage, handling and transit based on the strong assumption that most of the carbon in the 

feedstock lost during transit is immediately decomposed. To more accurately estimate the actual loss of 

carbon due to these losses, one would need to model the carbon storage and fluxes associated with the 

feedstock lost, which are likely to be a function of time. The number of years considered would be a 

policy decision; the longer the period, the larger the proportion of loss that would be counted. The

Framework tacitly assumes an infinitely long horizon that results in the release of all the carbon stored 

in the lost feedstock.

Products (PRODC): The removal of products from potential gross emissions is justified scientifically; 

however, the scientific justification for treating all products equally in terms of their impact on 

emissions is not clear. For some products (e.g., ethanol and paper), the stored carbon will be released 

rapidly while for other products, such as furniture, it might be released over a longer period of time. The 
21

Framework implicitly assumes that all products have infinite life-spans, an assumption without

justification or scientific foundation. For products that release their stored carbon rapidly, the 

consequences for the atmosphere are the same as for combustion of the feedstock. To precisely estimate 

the stores of products so as to estimate the amount of carbon released, one would need to track the stores 

as well as the fluxes associated with product pools. The stores of products could be approximated by 

modeling the amount stored over a specified period of time. 

A second way in which PRODC is used is as a means of prorating all area–based terms such as LAR, 

SITE-TNC and Leakage. This is potentially problematic because it makes the emissions embodied in coproducts dependent on the choice of regional scale at which LAR is estimated. As the size of the region 

contracts, LAR tends towards zero and the amount of gross emissions embodied in PRODC increases 

and exacerbates the implications of the scale sensitivity of the LAR value. 

Avoided Emissions (AVOIDEMIT): This term refers to transfers of emissions that would occur 

“anyway” from removal or diversion of non-growing feedstocks like corn stover and logging residues. 

In the Framework, feedstocks may be mathematically credited with avoided emissions if the residues 

would have decayed “anyway.” Specifically, AVOIDEMIT is added to Growth (GROW) in the 

numerator in determining the LAR or proportion of emissions that are offset by sequestration or avoided 

emissions. As with the Loss term, there is an implicit assumption of instantaneous decomposition that 

appears to be a simplifying assumption. While this may be a convenient assumption, it should be 

explained and justified. To improve scientific accuracy, the EPA could explore some sample 

calculations (as described below), taking into account regional differences in decay rates. Once this 

information is gathered and analyzed, the EPA may then need to make a decision that weighs scientific 

accuracy against administrative expediency and other factors. 

Since the concept reflected in “avoided emissions” is actually “equivalent field-site emissions,” it would 

be clearer to refer to it this way since emissions are not so much avoided as they are shifted to another 

venue. With residues left in the forest, some of the materials might take decades to fully decompose. For 

accuracy, the hypothetical store of carbon would have to be tracked. To approximate these stores, one 

could compute the average amount of carbon remaining after a period of years. 

The scientific theory behind losses and stores of ecosystem carbon was developed by Olson (1963) and 

could be applied to the fate of residues and slash in both forest and agricultural systems. The store of 

carbon in an ecosystem depends upon the amount of carbon being input (I) and the proportion of carbon 

lost per time unit, referred to as the rate-constant of loss (k). Specifically the relationship is I/k. In the 

case of residues or slash that are burned in the field or in a bioenergy facility, the store of carbon is 

essentially zero because most of the input is lost within a year (k> 4.6 per year assuming at least 99% of 

the material is combusted within a year). On the other hand, if the residue or slash does not lose its 

carbon within a year, the store of carbon would be greater than zero and, depending on the interval of 

residue or slash creation, could be greater than the initial input. Appendix C provides more information 

on the fate of residue after harvest and landscape storage of carbon. For example, if slash is generated 

every 25 years (I=100 per harvest area/25=4 per year) and the slash is 95% decomposed within 25 years 

(k=0.12 per year), one cannot assume a store of zero because the average ecosystem store in this case 

would actually be 33% of the initial input (4/0.12=33.3). If the input occurred every 5 years (I=100 per 

harvest/5=20 per year) for the same decay rate-constant, then the average store would be 167% of the 

initial input (20/0.12=167). Moreover, it cannot be assumed that because the rate-constant of loss (k) is 

high, that the stores will always be low. That is because the input (I) is a function of the interval of 

residue or slash generation; the shorter the interval of generation, the higher the effective input because a 
22

higher proportion of the forest or agricultural system is contributing inputs. For example, if there is 1 

unit of residue/slash generation per harvest, then an annual harvest on a system basis creates 1 unit of 

material; if there is 1 unit of residue/slash generation per harvest, then a harvest every 10 years creates 

an average harvest of 0.1 units (1 unit/10 years = 0.1 unit per year). This relationship means that if 

residue or slash is generated annually and 95% is lost to decomposition in that period, then the forest 

system could store 33% of the initial input (I/k=1/3). For the values of k usually observed in agricultural 

setting (50% per year), an annual input would lead to a store in excess of 145% of the initial input 

(I/k=1/0.69). Burning of this material would cause a decrease in carbon stores analogous to that of 

reducing mineral soil stores as accounted for in SITE_TNC, but this loss is not accounted for in the 

proposed Framework. 

There are several ways in which losses from residue/slash decomposition could be used in the 

Framework. One is to track the annual loss of carbon from decomposition. This would be analogous to 

tracking the regrowth of feedstock annually, but in this case it would be the annual decomposition loss. 

The annual decomposition loss would then be credited as equivalent to combustion as fuel. The 

advantage of this system is that it would track the time course of release. The disadvantage is that it 

increases transaction costs. An alternative based on a fuelshed (or other larger area) would be to 

calculate the average fraction of residue or slash that would remain over the harvest interval and subtract 

that from the amount harvested. The difference between the amount harvested and the amount that 

would have remained is an index of the equivalent amount of release via decomposition. For example, if 

10 metric tons of either residue or slash is created per year in a fuelshed and 65% of the slash would 

have decomposed on average over a given harvest interval, then decomposition would have been 

equivalent to a release of 65% of the amount of fuel used (6.5 metric tons). This would mean that 3.5 

metric tons that would have been stored was lost by combustion; hence 6.5 metric tons would be 

credited in the current calculation of LAR. However, if 35% of the slash would have decomposed on 

average over the harvest interval, then use of 10 metric tons as fuel would reduce carbon stores of 

residues and slash by 6.5 metric tons. This would result in a so-called “avoided emissions” credit of 3.5 

metric tons. 

In addition to considering actual decomposition losses, the Framework needs to consider the starting 

point of residue and slash harvest. The carbon released by combustion will be a function of the starting 

point, with systems that start with residues and slash having a different timeline of release than those 

that newly create residue and slash. The former will have the release rate linearly related to the harvest 

interval, whereas the latter will likely have a curvilinear relationship that is a function of the rateconstant of loss (k). 

Instead of a simplifying assumption of instantaneous decomposition, a more accurate calculation could 

be developed that determines a loss rate-constant appropriate to the material and climate to estimate the 

amount of carbon that could have been stored had the material not been burned. This amount could be 

approximated by using the relationships developed by Olson (1963) and reducing the number of 

calculations involved. When approximations are used, they should be checked against more precise 

methods to determine the magnitude of possible approximation errors. Several mechanisms could be 

used to simplify the estimation of these numbers, ranging from calculators that require entry of a few 

parameters (e.g., average amount of residue or slash generated, the area of source material, the interval 

of harvest) to look-up tables that are organized around the parameters used to generate them. While 

there is some uncertainty regarding the loss rate-constants, these sorts of parameters are routinely used 

in scientific assessments of the carbon cycle and their uncertainty is not much greater than any other 

parameter required by the Framework. 
23

The Framework should provide guidance on how logging residue will be distinguished from forest 

feedstock since that will influence the BAF for that biomass and create incentives to classify as much 

material as possible as residue and slash despite the fact that some of the “residue/slash” material such 

as cull trees would be “regenerated” via feedstock regrowth. 

Total Net Change in Site Emissions (SITE_TNC): This term is the annualized difference in the stock of 

land-based carbon (above and below ground, including changes in standing biomass and soil carbon) 

that results on the site where the feedstock is produced. 

The estimates of SITE_TNC will be site-specific and will depend on the knowledge about previous 

history of land use at that site, the specific agricultural or forestry management practices utilized and the 

length of time over which they have been practiced. To the extent that the use of bioenergy leads to a 

change in these practices relative to what would have been the case otherwise, it will be important to use 

an anticipated baseline approach to determine the stock of land based carbon in the absence of bioenergy 

and to compare that to the stock with the use of bioenergy. As discussed below in response to charge 

question 4(f), this anticipated baseline could be developed at a regional or national scale and include 

behavioral responses to market incentives. Alternatively, look-up tables could be developed based on 

estimates provided by existing large scale models such as CENTURY or Forestry and Agricultural 

Sector Optimization Model (FASOM) for feedstock based and region specific SITC_TNC estimates. 

It should be noted that soil carbon sequestration is not a permanent reduction in CO2 emissions. The 

Framework, however, treats permanent reductions in emissions, for example, due to a reduction in the 

LOSS of biomass to be equivalent to reductions due to an increase in soil carbon sequestration which 

could be temporary. Since soil carbon sequestration is easily reversible with a change in land 

management practices, the implementation of this Framework will need to be accompanied by frequent 

monitoring to determine any changes in soil carbon stocks and to update the BAF value for a facility. 

Sequestration (SEQP): This term from EPA’s Framework refers to the proportion of feedstock carbon 

embodied in post-combustion residuals such as ash or biochar. Including sequestration in the 

Framework is appropriate; however, the approach taken is subject to the same problems as those 

described for Products. There is no scientific literature cited to support the idea that all the materials 

produced by biogenic fuel use do not decompose. This is the subject of ongoing research, but it seems 

clear that these materials do decompose. The solutions to creating a more realistic and scientifically 

justified estimate are the same as for the Products term (see above). 

Leakage (LEAK): The Framework includes this term for leakage but is silent on the types of leakage 

that would be included and how leakage would be measured. EPA representatives said the Framework

did not provide a quantification methodology for leakage because assessing leakage requires policy- and 

program-specific details that are beyond the scope of the report. However, there are several conceptual 

and implementation issues that merit further discussion in the Framework. 

The use of biogenic feedstocks could lead to leakage by diverting feedstocks and land from other uses 

and affecting the price of conventional forest and agricultural products, which can lead to indirect land 

use changes that release or increase carbon stored in soils and vegetation. The use of these feedstocks 

could also affect the price of fossil fuels by lowering demand for them and increasing their consumption 

elsewhere (also referred to as the rebound effect on fuel consumption); this would offset the greenhouse 

gas savings from the initial displacement of fossil fuels by bioenergy (Chen and Khanna 2012). Leakage 
24

effects will vary by feedstock and location and could be positive (if they lead to carbon emissions 

elsewhere) or negative (if they lead to carbon uptake activities). As will be discussed in Section 3.4 [in 

response to question 4(f)], the latter could arise, for example, if increased demand for biomass and 

higher prices generate incentives for investment in forest management that increases forest carbon 

sequestration. Some research has shown that when a future demand signal is strong enough, expectations 

about biomass demand for energy (and thus revenues) can reasonably be expected to produce 

anticipatory feedstock production changes with associated changes in land management and land-use 

(e.g., Sedjo and Sohngen, in press, 2012). Thus price changes can lead to changes in consumption and 

production decisions outside the boundary of the stationary source, even globally.

While the existence of non-zero leakage is very plausible, the appropriateness of attributing emissions 

that are not directly caused by a stationary facility to that facility has been called into question 

(Zilberman et al. 2011). While first principles in environmental economics show the efficiency gains 

from internalizing externalities by attributing direct environmental damages to responsible parties, they 

do not unambiguously show the social efficiency gains from attributing economic or environmental 

effects (such as leakage) that occur due to price changes induced by its actions to that facility 

(Holcombe and Sobel, 2001). Moreover, leakage caused by the use of fossil fuels is not included in 

assessing fossil emissions generated by a stationary facility. Liska and Perrin (2009) show that military 

activities to secure oil supplies from the Middle East lead to indirect emissions that could increase the 

carbon intensity of gasoline. Thus, the technical basis for attributing leakage to stationary sources and 

inherent inconsistency involved in including some types of leakage and for some fuels makes the 

inclusion of leakage as a factor in the BAF calculation a subjective decision. Including some types of 

leakage (for example, due to agricultural commodity markets) and not others (such as those due to the 

rebound effect in fossil fuel markets) and for biomass and not fossil fuels would be a policy decision 

without the underlying science to support it. 

Empirically, assessing the magnitude of leakage is fraught with uncertainty. Capturing leakage would 

entail using complex global economic models that incorporate production, consumption and land use 

decisions to compare scenarios of increased demand for biogenic feedstocks with a baseline scenario 

without increased demand. Global models that include trade across countries in agricultural and forest 

products can aid in determining the leakage effects on land use in other countries. Global models of the 

forestry sector include Sedjo and Sohngen (2012) and Ince et al. (2011). Existing models would need to 

be expanded to include the multiple lignocellulosic feedstocks considered in this Framework that can 

compete to meet demand for bioenergy to determine net leakage effects. Methods would then need to be 

developed to assign leakage factors to individual feedstocks. The existing literature assessing the 

magnitude of leakage from one use of a biogenic feedstock (corn ethanol) shows that its overall 

magnitude in the case of leakage due to biofuel production is highly uncertain and differs considerably 

across studies and within a study depending on underlying assumptions (Khanna et al. 2011; Khanna

and Crago 2012). Other feedstock-use combinations would also need to be evaluated. If the magnitude 

of leakage is plagued with too much uncertainty, if possible, its direction should at least be stated and 

recognized in making policy choices. Depending on the level of uncertainty, supplementary policies 

might be possible to reduce leakage due to changes in land use, such as restrictions on the types of land 

that could be used to produce the biogenic feedstocks and the types of biogenic feedstocks that could be 

used to qualify for a BAF less than 1. Some of these implementation issues with estimating BAF and 

leakage will be discussed further in Section 3.4.
25

3(b). Does SAB support EPA’s distinction between policy and technical considerations 

concerning the treatment of specific factors in an accounting approach?

A clear line cannot be drawn between policy and technical considerations in an accounting approach. In 

fact, the lack of information on EPA’s policy context and the menu of options made it more difficult to 

fully evaluate the Framework. Because the reasonableness of any accounting system depends on the 

regulatory context to which it is applied, the Framework should describe the Clean Air Act motivation 

for this proposed accounting system, including how the agency regulates point sources for greenhouse 

gases and other pollutants. The document should make explicit the full gamut of Clean Air Act policy 

options for how greenhouses gases could be regulated, including any potential implementation of carbon 

offsets or certification of sustainable forestry practices. The Framework also should describe the EPA’s 

legal boundaries regarding upstream and downstream emissions. Technical considerations can influence 

the feasibility of implementing a policy just as policy options can influence the technical discussion. The 

two need to go hand in hand rather than be treated as separable.

The Framework explicitly states that it was developed for the policy context where it has been 

determined that a stationary source emitting biogenic CO2 requires a means for “adjusting” its total 

onsite biogenic emissions estimate on the basis of information about growth of the feedstock and/or 

avoidance of biogenic emissions and more generally the carbon cycle. However, in the discussion on the 

treatment of specific factors it states in several places that this treatment could depend on the program or 

policy requirements and objectives. Certain open questions described as “policy” decisions (e.g., the 

selection of regional boundaries, marginal versus average accounting, inclusion of working or nonworking lands, inclusion of leakage) made the evaluation of the Framework difficult. Clearly, the policy 

context matters and the EPA’s reticence in describing the policy context and in taking positions on open 

questions (as well as lack of implementation details) meant that the Framework was inadequately 

defined for proper review and evaluation. 

Specifically, if the policy context is changed – for example, if carbon accounting is needed to support a 

carbon cap and trade or carbon tax policy – then the appropriateness of the Framework would need to be 

evaluated relative to alternative approaches such as life cycle analysis for different fuel streams. 

Modifying how certain factors are measured or included may not be sufficient. In fact, a different 

Framework would likely be needed if a national or international greenhouse gas reduction commitment 

exists. Furthermore, the BAFs developed for regulating the emissions from stationary sources would 

likely conflict with measures of greenhouse gas emissions from bioenergy used in other regulations such 

as California’s cap and trade system for regulating greenhouse gases.

Economic research has shown that the most cost-effective way to reduce greenhouse gas emissions (or 

any other pollution) is to regulate or tax across all sources until they face equal marginal costs. The most 

cost-effective solution would involve setting carbon limits (or prices) on an economy-wide basis and not 

selectively for particular sources or sectors. Given the EPA’s limited authority under the Clean Air Act, 

the most efficient economy-wide solution is not within its menu of policy choices. EPA’s regulation of 

stationary sources will exclude other users of biomass that also have equivalent impacts on the carbon 

cycle as well as downstream emissions from consuming the products produced by these facilities. Note 

that biogenic emissions accounting would still be an issue even under an economy-wide emissions 

policy. 
26

3(c). Are there additional factors that EPA should include in its assessment? If so, please specify 

those factors.

As stated above, for agricultural biomass from energy crops and crop residues, the factors included in 

the Framework capture most of the direct off-site adjustments needed to account for the changes in 

carbon stocks caused by a facility using agricultural feedstocks although they do not account for 

leakage. However, an anticipated baseline is needed for soil carbon, residue disposition and land 

management changes. For forest biomass, the Framework needs to incorporate the time path of carbon 

accumulation in forests (after energy emissions from harvested roundwood) and forest investment and 

multi-stand decisions. As discussed in Section 3.1, EPA should consider the time path of the “anyway” 

emissions that would have occurred on the land if logging residue were not used for energy production

and weigh the benefits of scientific accuracy against the administrative simplicity of assuming 

instantaneous decomposition. For municipal solid waste biomass, the Framework needs to consider 

other gases and CH4 emissions from landfills. Given that methane emissions from landfills are 

sometimes not captured, crediting waste material for avoided emissions of methane may be 

inappropriate. As the Framework states, the carbon impact of using waste for energy production in 

combustion facilities should nonetheless be subjected to a biogenic accounting framework. It should be 

gauged relative to the CH4 emissions, if any, that would be released during decomposition in a landfill.

N2O emissions, especially from fertilizer use, should also be considered. Furthermore, the inclusion of 

non-CO2 greenhouse gases in general should be consistent between biogenic and fossil fuel accounting. 

For instance, there are also transportation -related emissions losses in the delivery of natural gas. 

3(d). Should any factors be modified or eliminated?

For reasons discussed above, factors such as PRODC, AVOIDEMIT and SEQP could be improved by 

incorporating the time scale over which biomass is decomposed or carbon is released back to the 

atmosphere. LAR needs to be modified to be scale insensitive and to address additionality. Factors can 

be separated by feedstocks according to their relevance for accounting for the carbon emissions from 

using those feedstocks. For example, GROW and leakage may not be relevant for crop and forest 

residues.
27

3.4. Accounting Framework

Charge Question 4: EPA's Accounting Framework is intended to be broadly applicable to 

situations in which there is a need to represent the changes in carbon stocks that occur offsite, 

beyond the stationary source, or in other words, to develop a "biogenic accounting factor" (BAF) 

for biogenic C02 emissions from stationary sources.

Question 4(a). Does the Framework accurately represent the changes in carbon stocks that occur 

offsite, beyond the stationary source (i.e., the BAF)?

For agricultural biomass, the variables in EPA’s proposed equation for BAF represent the basic factors 

necessary for estimating the offsite carbon change associated with stationary source biomass emissions, 

including changes in storage of carbon at the harvest site. For short accumulation feedstocks, where 

carbon accumulation and “anyway” emissions are within one to a few years (i.e., agricultural residues, 

perennial herbaceous crops, mill wood wastes, other wastes), with some adjustments to address 

estimation problems (including an anticipated baseline for soil carbon changes, residue disposition and 

land management) and careful consideration of data and implementation, the Framework can accurately 

represent carbon changes offsite. However, for long accumulation feedstocks where carbon 

accumulation and “anyway” emissions occur over decades [i.e., wood harvested specifically for energy 

use (roundwood) and logging residue], the Framework does not accurately account for changes in 

carbon stocks offsite for several reasons discussed below in response to charge question 4(b).

The Framework also does not consider other greenhouse gases (e.g., N2O from fertilizer use and CH4

emissions from landfills). Excluding CH4 because it is not “CO2” is not a legitimate rationale. It would 

need to be included to estimate the “difference in carbon dioxide equivalent (CO2e) the atmosphere 

sees.” In addition, excluding CH4 emissions from landfills is inconsistent with the Framework’s purpose 

of accounting for displaced on-site changes in CO2. For the same reasons, the basis for excluding N2O 

emissions from biomass production is unclear. It also needs to be included to estimate the net changes in 

atmospheric greenhouse gases. Accounting for N2O from fertilization would be consistent with tracking 

changes in soil carbon which are a response to agricultural management systems that include fertilizer 

decisions. 

Question 4(b). Is the Framework scientifically rigorous? 

The SAB did not find the Framework to be sufficiently comprehensive. Specifically, the SAB identified 

a number of deficiencies that need to be addressed. 

Time scale: As discussed previously, one deficiency in the Framework is the lack of proper 

consideration of the different time scales inherent in the carbon cycle and the climate system that are 

critical for establishing an accounting system. This is a complicated subject because there are many 

different time scales that are important for the issues associated with biogenic carbon emissions. 

Scientific understanding of the time scale over which the climate system responds to cumulative 

emissions implies that the carbon release caused by harvesting and combusting biomass at stationary 

sources is a serious problem if carbon storage, on average, is reduced over long periods of time. So long 

as rates of growth across the landscape are sufficient to compensate for carbon losses from harvesting 
28

over the long run, the climate system is less sensitive to the imbalance in the carbon cycle that might 

occur in the short run from harvesting of biomass for bioenergy facilities. A scientifically rigorous 

evaluation of the impact of biomass harvest on the carbon cycle should consider the temporal 

characteristics of the cycling as well as the spatial simultaneous decisions made across stands and plots. 

Annual accounting of carbon stocks, while helpful in tracking net carbon emissions, is likely to give an 

inaccurate assessment of the overall climate and atmospheric carbon cycle impacts.

The Framework also does not consider the length of time it takes ecosystems to respond to disturbances, 

such as those due to the harvesting of biomass, nor does it consider the spatial heterogeneity in this 

response. This has implications for the accuracy with which the impact of different land management 

strategies on carbon stocks in soil and vegetation is estimated. 

The Framework subtracts the emissions associated with products – including ethanol, paper, and timber

– from the calculation of emissions from a stationary source, through the PRODC term. While the EPA 

may not have the discretion to treat all emissions equally, distinguishing between immediate emissions 

from the facility and downstream emissions (as these products will inevitably be consumed within a 

short period of time) does not make sense scientifically. From the perspective of the carbon cycle and 

the climate system, all these facilities extract biomass from the land and the vast majority of that 

biomass is converted to carbon dioxide, adding to cumulative emissions and, hence, a climate response. 

Spatial scale: There is no peer reviewed literature cited to support the delineation of spatial scales for 

biogenic CO2 accounting and different carbon pools to be accounted for at different spatial scales. For 

example, the atmospheric impact of feedstocks is gauged on a regional basis in terms of its impact on 

forest carbon stocks (except for case study 5) while impacts due to land use change are accounted for at 

the site level. 

The Framework’s use of a regional scale for accounting for the net changes to the atmosphere is an 

artificial construct developed to (a) avoid the need for site-specific chain of custody carbon accounting 

with separate streams for each feedstock and (b) as an alternative to capturing changes in carbon stocks 

over time. The calculation of LAR uses regional landscape wide carbon changes but does not actually 

estimate changes attributable to biomass demand (see next discussion). This approach attempts to 

simplify implementation using available forest inventory data and circumvents the need for accounting 

for changes in carbon stocks specific to the site or feedstock sourcing region (fuelshed), which may be 

more complex, costly and difficult to verify. However, as noted, it doesn’t provide an actual estimate of 

carbon changes due to stationary source biomass demand, and it makes the estimate of the BAFs 

sensitive to the choice of the spatial region chosen for accounting purposes. As shown by case study 1, 

there are significant implications of this choice for the emissions attributed to a facility. 

Additionality: A key question is whether the harvesting of biomass for bioenergy facilities is having a 

negative impact on the carbon cycle relative to emissions that would have occurred in the absence of 

biomass usage. This requires determining what would have happened anyway without the harvesting 

and comparing the impact with the increased harvesting of biomass for bioenergy in order to isolate the 

incremental or additional impact of the bioenergy facility. While the Framework discusses the “business 

as usual” or “anticipated future baseline” approach, it implements a reference point approach that 

assesses carbon stocks on a regional basis at a given point in time relative to a historic reference carbon 

stock. 
29

For forest carbon stocks, the choice of a fixed reference point may be the simplest to execute, but it does 

not actually address the question of the extent to which forest stocks would have been growing/declining 

over time in the absence of a particular bioenergy facility. The use of a fixed reference point baseline 

implies that forest biomass emissions could be considered carbon neutral if forest stocks are increasing. 

This is simply an artifact based on the choice of the baseline that will be used. The problem is thus: a 

region with decreasing carbon stocks may in actuality have greater carbon stocks than it would have had

without the increased harvesting of biomass. Similarly, a region with increasing carbon stocks may have 

less stores of carbon than would be the case without the facility using biomass. By default, this approach 

creates “sourcing” and “non-sourcing” regions. Thus, a carbon accumulating region is a “source” of in 

situ carbon that can be given to support biomass use, and a carbon losing region is a “non-source” of 

carbon and cannot support biomass use. The reference year approach provides no assurances at all that a 

“source” region is gaining carbon due to biomass use, or that a “non-source” region is losing carbon due 

to biomass use. 

For example, for roundwood use under the Framework, a region may have carbon accumulation with 

respect to the reference year (and be assigned LAR=1 according to the Framework); however, harvest of 

a 150+ year old forest in the region for energy production would not be counted in a facility’s 

greenhouse gas emissions even though there is less carbon storage than there would have been otherwise 

and only a portion of the forest’s carbon would be recovered within the next 100 years. To estimate the 

“difference in atmospheric greenhouse gases” over some period, one must estimate how carbon 

accumulation differs between a biomass use case and a case without biomass use (business as usual 

case). 

Assessing uncertainty: The Framework acknowledges uncertainty but does not discuss how it will be 

characterized and incorporated to assess the potential uncertainty in the estimate of the BAF value.

Selecting an acceptable risk level is a policy decision but characterizing uncertainty and risks is a 

scientific question. There are numerous drivers that can change biogenic carbon stocks, even in the 

absence of biomass harvesting for energy. These include changes in economic conditions, domestic and 

international policy and trade decisions, commodity prices, and climate change impacts. There is 

considerable uncertainty about the patterns of future land use, for example, whether land cleared for 

bioenergy production will stay in production for decades to come. The potential impact of these forces 

on biogenic carbon stocks and the uncertainty of accounting need to be considered further. Ideally, the 

EPA should put its BAF estimates into context by characterizing the uncertainties associated with BAF 

calculations and estimating uncertainty ranges. This information can be used to give an indication of the 

likelihood that the BAFs will achieve the stated objective. The uncertainty within and among variables 

for any estimate may vary widely between feedstocks and across regions. Finally, it should be pointed 

out that while parameter uncertainty is important to consider throughout the Framework, alternative 

policy options (e.g., categorical inclusion and exclusion) do not have parameter uncertainty yet their 

effect on atmospheric carbon is also uncertain.

Leakage: The Framework states that the likelihood of leakage and the inclusion of a leakage term will 

be based on a qualitative decision. There is essentially no guidance in the document about how leakage 

might be quantified and no examination of the literature regarding possible leakage scenarios (consider 

Murray et al. 2004). A number of statements/assumptions were made regarding the area and intensity of 

wood harvest increases to accommodate biomass access. There was no examination of the scientific 

literature on wood markets and therefore no science-based justification for these 

statements/assumptions.
30

Other areas: Other areas that require more scientific justification include assumptions regarding 

biomass losses during transport and their carbon implications, the choice of a 5-year time horizon 

instead of one that considered carbon cycling, and the decision to include only CO2 emissions and 

exclude other greenhouse gas emissions. Additionally, assumptions about the impacts of harvests on soil 

carbon and land use changes on carbon sequestration need to be more rigorously supported. 

Inconsistencies: Below are some inconsistencies within the Framework that should be resolved or 

justified: 

(1) Consistency with fossil fuel emissions accounting: Fossil fuel feedstock emissions accounting 

from stationary sources under the Clean Air Act are not adjusted for offsite greenhouse gas 

emissions and carbon stock changes. Does that imply that by default BAFs should be zero as 

well? No, because, unlike fossil fuels, biogenic feedstocks have carbon sequestration that occurs 

within a timeframe relevant for offsetting CO2 emissions from the biomass combustion. For 

comparability, however, biomass and fossil fuels emissions accounting should be similar for 

other emissions categories. These include non-CO2 greenhouse gas emissions, losses, leakage, 

and fossil fuel use during feedstock extraction, production and transport. This issue is also 

discussed in Section 3.3.1.

(2) Biogenic and fossil fuel emissions accounting for losses: The Framework’s handling of carbon 

losses during handling, transport, and storage introduces an inconsistency between how fossil 

emissions are counted at a stationary source and how biomass emissions are counted. For 

biomass emissions the Framework includes emissions associated with loss of feedstock between 

the land and the stationary source. For natural gas the emissions attributed to the stationary 

source do not include fugitive greenhouse gas emissions from gas pipelines. Why would loss 

emissions be included for biomass when they are not included for natural gas? 

(3) Inconsistency in the consideration of land management and the associated greenhouse gas flux 

accounting: The Framework accounts for soil carbon stock changes, which are a function of the 

land management system, soil, and climatic conditions. However, it does not account for the 

non-CO2 greenhouse gas changes like N2O that are jointly produced with the soil carbon 

changes. Soil carbon changes influence both the below and above ground carbon stock changes 

associated with changes in the land management system. 

(4) Reference year and business as usual (BAU) baseline use: The Framework proposes using a 

reference year approach: however, it implicitly assumes projected behavior in the proposed 

approach for accounting for soil carbon changes and municipal waste decomposition. 

(5) Definition of soil. There is a good deal of variation in the Framework as to the definition of 

“soil.” At one point it appears to be defined as all non-feedstock carbon such as slash, surface 

litter, and dead roots as well as carbon associated with mineral soil. In other places, the 

Framework seems only to consider the carbon associated with mineral soil. Unfortunately this 

inconsistency in the use of the term “soil” creates confusion regarding interpretation and 

implementation. When soil is defined as non-feedstock carbon (that is all forms of dead carbon) 

and then implemented as mineral soil carbon (one form of dead carbon), it is impossible to 

ensure a mass balance as dead material above- and belowground is accounted for in one place, 

but then not elsewhere. Inconsistent definitions of soil carbon mean that statements regarding the 

impact of management cannot be unequivocally assessed. For example, if the broader definition 
31

of soil is being invoked, then the statement that management of forests can reduce soil carbon 

could be justified (Harmon et al. 1990; Johnson and Curtis 2001). However, if the narrower 

definition of mineral soil carbon is being invoked, then there is very little empirical evidence to 

justify this statement (Johnson and Curtis 2001); and in fact there is evidence that forest 

management can at least temporarily increase mineral soil carbon. 

Soil carbon should be defined and used consistently throughout the document. If defined 

broadly, then consistent use of subcategories would eliminate much confusion. For example, if 

organic horizons such as litter are part of the soil, then consistently referring to total soil, organic 

soil horizons, and mineral horizons would be essential. Had that been done, the confusion about 

the impact of forest management on soil carbon would have been eliminated as management can 

greatly influence organic horizons, but have little effect on mineral horizons. If defined narrowly 

to only include mineral soil, then the EPA should develop a terminology for the other carbon 

pools (e.g., organic horizons, aboveground dead wood, and belowground dead wood) that 

ensures that mass balance is possible. 

To define soil carbon, EPA should consider the merits of an aggregated soil term versus 

subcategories based on source of the carbon, the controlling processes, and their time dynamics. 

While the aggregated term “soil” is simple, it potentially combines materials with very different 

sources, controlling processes, and time dynamics, creating an entity that will have extremely 

complex behavior. It also creates the temptation of a broad term being used for a subcategory. 

Separating into woody versus leafy materials would account for different sources and to some 

degree time dynamics. In contrast, separating into feedstock versus non-feedstock material (as 

appears to be done in the Framework) creates a poorly defined boundary as woody branches 

would be soil if they are not used, but could be viewed as not being soil if they are. A feedstockbased system also does not separate materials into more uniform time dynamics (if leaves and 

wood are not harvested, then materials with lifespans that differ an order of magnitude are 

combined). Controlling processes, be they management or natural in nature, differ substantially 

for above- versus belowground carbon; hence they should be divided. 

Underlying the need for a clear definition of soil in the document is the complexity of soil 

outcomes that differ based on conditions. Some noteworthy publications from forest soil science 

might have informed the Framework’s treatment of soil carbon in forest ecosystems (Alban and 

Perala 1992; Mattson and Swank 1989; Binkley and Resh 1999; Black and Harden 1995; 

Edwards and Ross-Todd 1983; Gilmore and Boggess 1963; Goodale et al. 2002; Grigal and 

Berguson 1998; Homann et al. 2001; Huntington 1995; Johnson and Curtis 2001; Laiho et al. 

2003; Mroz et al. 1985; Nave et al. 2010; Richter et al. 1999; Sanchez et al. 2007; Schiffman and 

Johnson 1989; Selig et al. 2008; Tang et al. 2005; Tolbert et al. 2000). 

Question 4(c). Does the Framework utilize existing data sources?

First, and most importantly, the Framework does not provide implementation specifics. Therefore, it is 

difficult to assess data availability and use. These issues are discussed here and in the sections that 

follow. 

A more meaningful question is “Are the proposed data sets adequate to account for the effects of 

biogenic carbon cycling on CO2 emissions from a facility?” The Framework does use existing data, but 
32

the data are not adequate to attribute emissions to a facility. For example, the Framework mentions the 

use of the USDA Forest Service’s Forest Inventory and Analysis (FIA) data at some unspecified scale. 

However, carbon stock change data are likely not very accurate at the scale of the agricultural or forest 

feedstock source area for a facility. 

The Framework requires data and/or modeling of land management activities and their effects on CO2

emissions and stock changes. For example, for agricultural systems, data are required on the type of 

tillage and the effect of such tillage on soil carbon stocks for different soil types and climatic conditions. 

Such data are not likely to be available at the required scales. In one of the case studies, for example, the 

Century model is used to model soil carbon stocks. Is the use of this particular model proposed as a 

general approach to implement the Framework? Since this model generally addresses soil carbon only to 

a depth of 20 centimeters, does that represent a boundary for the Framework? Recent work has shown 

that such incomplete sampling can grossly misestimate changes in soil carbon for agricultural practices 

such as conservation tillage (Baker et al. 2007; Kravchenko and Robertson 2011). Which version of the 

model would be run? Would EPA run this model and select parameters appropriate for each feedstock 

production area for each facility? How robust are the predictions of this model for the range of soils, 

climatic conditions, and management practices expected to be covered by the Framework? Could some 

other model be used that produces different results for a given facility?

The Framework implies that data are required from individual feedstock producers. Collecting such data 

would be costly and burdensome. Additionally, to the extent that feedstocks are part of commodity 

production and distribution systems that mix material from many sources, it is not likely to be feasible to 

determine the source of all feedstock materials for a facility.

The Framework includes a term for leakage but eschews the need to provide any methodology for its 

quantification. Example calculations are carried out for leakage in one of the case studies without any 

explanation for their source. However, leakage can be positive or negative, and while many publications 

speculate about certain types of leakage, no data are presented, nor are data sources for different types of 

leakage suggested or discussed. The Framework does provide an example calculation of leakage in the 

footnote to a case study, but this does not a substitute for a legitimate discussion of the literature and 

justification and discussion of implications of choices. In addition, such data are unlikely to be available 

at the scales required. The implications and uncertainties caused by using some indicator or proxy to 

estimate leakage need to be discussed. If leakage cannot be estimated well, is it possible to put an error 

range on the leakage value (e.g., a uniform distribution) and assess the impact of this uncertainty on the 

overall uncertainty in the BAF value? For some cases, such as the conversion of agricultural land to 

biomass production from perennial crops, leakage may be described as likely increasing net emissions. 

In cases such as this where prior research has indicated directionality, if not magnitude, such 

information should be used. As previously noted, there is also a consistency issue with the reference 

year approach because leakage estimation will require an anticipated baseline approach of some sort. 

In summary, it is not clear that all of the data requirements of the Framework can be met. Furthermore, 

even if the data are acquired, they may not be adequate to attribute emissions to a facility.

Question 4(d). Is it easily updated as new data become available?

In principle it would be feasible to update the calculations as new data become available. Some kinds of 

data, such as those from FIA, are updated periodically and could be used to update the analysis.
33

However, as discussed for other sub-questions, it is not clear exactly what data and resolution are 

required and whether all the required data are readily available. 

The Framework uses an annual or five-year interval for updating calculations. For some kinds of data, 

such as soil and forest carbon stocks, this interval is too short to detect significant changes based on 

current or feasible data collection methodologies. This implies that statistical or process models would 

be used to estimate short-term changes for reporting purposes. 

Lastly, if BAF is not under the control of the facility, frequent calculation of the BAF would introduce 

considerable uncertainty for the facility. This would particularly be the case if a leakage factor were 

included in the BAF and would need to be updated frequently with changes in market conditions.

However, if the accounting is infrequent, shifts in the net greenhouse gas impact may not be captured. 

Clearly, the EPA will have to weigh tradeoffs between the accuracy of greenhouse gas accounting and 

ease of implementation and other transactions costs.

Question 4(e). Is it simple to implement and understand?

It is neither. While the approach of making deductions from the actual emissions to account for 

biologically based uptake/accumulation is conceptually sound, it is not intuitive to understand because it 

involves tracking emissions from the stationary source backwards to the land that provides the feedstock 

rather than tracking the disposition of carbon from the feedstock and land forwards to combustion and 

products. The Framework also appears to be difficult to implement, and possibly unworkable, especially 

due to the many kinds of data required to make calculations for individual facilities. Additionally, the 

factors (variable names) in the Framework do not match those used in the scientific literature and may 

be misunderstood. Lastly, many elements of the Framework are implicit rather than explicit. For 

example, the time frame during which changes in atmospheric greenhouse gases will be assessed is not 

explicit. The time frame for specific processes is often implicit, such as the emissions of CO2 from 

biomass that is lost in transit from the production area to the facility; this loss is assumed to be 

instantaneous. 

Much more detailed information is required about how the Framework would be implemented. It would 

be helpful to know the specific data sources and/or models to be used. To assess the adequacy of data,

more information is needed on implementation and the degree of uncertainty acceptable for 

policymakers to assign BAF values. 

Question 4(f). Can the SAB recommend improvements to the framework to address the issue of 

attribution of changes in land-based carbon stocks?

The Framework uses a reference year baseline approach to determining BAF in combination with a 

regional spatial scale. As mentioned in response to charge question 4(b), this approach is not adequate 

in cases where feedstocks accumulate over long time periods because it does not allow for the estimation 

of the incremental effect on greenhouse gas emissions over time of feedstock use. To gauge the 

incremental effect on forest carbon stocks due to the use of forest-derived woody biomass (specifically, 

the value of the LAR), an anticipated baseline approach is needed. This involves estimating a “business 

as usual” trajectory of emissions and forest stocks and comparing it with alternate trajectories that 

incorporate increased demand for forest biomass over time. The anticipated baseline approach should 

also be applied to determine soil carbon for all types of feedstocks for forest types, soils, residue, waste 

disposition and land management. An anticipated baseline approach (comparing “with” and “without” 
34

scenarios) was used by EPA in the development of its Renewable Fuel Standard (Federal Register, 

2012).

An anticipated baseline approach must incorporate market effects even when direct effects of the use of 

biogenic feedstocks on carbon emissions are being estimated. The projected baseline level of forest 

carbon stocks will need to be compared with the level in the case when there is demand for roundwood 

for bioenergy to assess the change in forest stocks due to the demand for bioenergy. The case with 

demand for bioenergy should consider the possibility that investment in long-lived trees could be driven 

by expectations about wood product prices and biomass prices, leading landowners to expand or retain 

land in forests, plant trees, shift species composition, change management intensity and adjust the timing 

of harvests. The role of demand and price expectations/anticipation is well developed in the economics 

literature (e.g., see Muth 1992) and also in the forest modeling literature (Sedjo and Lyon 1990; Adams 

et al. 1996; Sohngen and Sedjo 1998), which includes anticipatory behavior in response to future forest 

carbon prices and markets (Sohngen and Sedjo 2006; Rose and Sohngen 2011). The U.S. Energy 

Information Administration (EIA) has projected rising energy demands for biogenic feedstock based on 

market and policy assumptions, which could be met from a variety of sources, including energy crops 

and residues, but also short rotation woody biomass and roundwood (EIA 2012; Sedjo 2010; Sedjo and 

Sohngen 2012). The extent to which price expectations and anticipation of future demand for bioenergy 

are going to drive forest management decisions, and regional variations in them, would need to be 

empirically validated. One study shows forest carbon change in a decade (and thereafter) that exceeds 

the modeled increased cumulative wood energy emissions over the decade (Sedjo and Tian, in press, 

2012). This would be the case if demand is anticipated to increase in the future. Some other modeling 

studies suggest more limited responses to increased wood energy demand that differ across regions. One 

such model for the United States indicates a large response in the South, in the form of less forest 

conversion to non-forest use, but much less response in the North and West (USDA FS 2012; Wear 

2011). 

To capture both the market, landscape and biological responses to increased biomass demand, a 

bioeconomic modeling approach is needed with sufficient biological detail to capture inventory 

dynamics of regional species and management differences as well as market resolution that captures 

economic response at both the intensive (e.g., changing harvest patterns, utilization or management 

intensity) and extensive margins (e.g., land use changes). While several models have these features 

[USDA Forest Service Resources Planning Act (RPA) models in Wear 2011; Sub-regional Timber 

Supply in Abt et al. in press 2012; Forest and Agricultural Sector Optimization Model (FASOM) in 

Adams et al. 2005; and the Global Timber Market Model (GTMM) in Sohngen and Sedjo 1998], they 

differ in scope, ecological and market resolution, and how future expectations are formed. FASOM and 

GTMM employ dynamic long term equilibria that adopt the rational expectations philosophy that 

decisions incorporate expectations about future prices and market opportunities. In the RPA and SRTS 

models, agents respond to current supply, demand, and price signals so that expectations are assumed to 

be driven by current market conditions. While the rational expectations approach has internal logical 

consistency and can better simulate long-term structural change, it is not designed for prediction but 

instead to evaluate potential futures and deviations between futures. These models should incorporate 

the multiple feedstocks (including crop and logging residues) from the agricultural and forest sectors 

that would compete to meet the increased demand for bioenergy. 

Energy policies can influence the mix of feedstocks used, such as the use of logging residues and the 

level of projected traditional wood demand, and thus the impact of woody bioenergy demand on timber 

markets (Daigneault et al. in press 2012). A lower level of timber demand from pulp and paper mills and 
35

sawmills, for example, will lead to lower harvest levels and fewer available logging residues. If only 

residues are allowed to qualify as renewable, then the woody bioenergy industry is explicitly tied to the 

future of the traditional wood industries. However, if roundwood is used for bioenergy, then the market 

outcome is more complicated. A lower level of traditional harvest could lead to fewer available residues 

(which could raise the price of residues and set a physical upper limit on residue supply), but could also 

lead to higher inventory levels and lower roundwood prices, which would favor increased roundwood 

utilization for bioenergy. Modeling the interaction across traditional wood consumers, bioenergy 

consumers, changes in the utilization and mix of products and the displacement of one wood consumer 

by another as markets evolve will be difficult, but could have a significant impact on the estimate of the 

carbon consequences of bioenergy use. 

As with any modeling, uncertainties will need to be assessed. Models that include price expectations 

effects or the impact of current year prices would need to be validated. However, validation means 

different things for different kinds of models. For an econometric model, reproducing history is a form 

of validation, as is evaluating errors in near-term forecasts. Simulation models are not forecast models. 

They are designed to entertain scenarios. Validation for simulation models is evaluating parameters and 

judging the reasonableness of model responses – both theoretically and numerically – given 

assumptions. Evaluation will help improve representation of average forest and agricultural land 

management behavior. Evidence affirming or indicating limitations of the effect of prices on investment 

in retaining or expanding forest area across various U.S. regions may be found by a review of empirical 

studies of land use change.

Selection of an appropriate model requires judgment and understanding of the structure and assumptions 

of alternative models and their strengths and weaknesses. This could be supplemented with one or more 

approaches to choosing a model. These include validation of existing models at the relevant temporal 

and spatial scale by a means appropriate to the model type, as well as using more than one model to 

compare and triangulate outcomes. Note that models of different types (e.g., projections vs. forecasting 

models) require different types of evaluation. 

The anticipated baseline approach could be based on a national/global scale model or a regional scale 

after weighing the strengths and weaknesses of the two approaches. An example of a regional scale 

model is that by Galik and Abt (2012) where they tested the effects of various scales on greenhouse gas 

outcomes and found that in the southern United States, market impacts (negative leakage) had a 

significant impact on forest carbon impacts, but the results were dependent on time period evaluated and 

were particularly sensitive to scale. The authors evaluated carbon consequences of bioenergy impacts 

from stand level to state level and found that as scale increased, market responses mitigated forest 

carbon impacts. In addition to being sensitive to scale, another disadvantage of the regional scale models 

is that they would not account for leakage across different regions. However, regional models can 

incorporate greater heterogeneity in forest growth rates, their carbon impacts and in the price 

responsiveness of forest management decisions. The SAB has not conducted a detailed review of these 

models to suggest which model and which scale would be the most appropriate.

While market effects are important, there is value in making separate estimates of biological land carbon 

changes alone (without market effects). Specifically, biophysical process response modeling results are a 

critical input to economic modeling. Ecosystem modeling is not a substitute for economic modeling, 

which is necessary to estimate behavioral changes driven by biomass feedstock demand that drives

changes in emissions and sequestration. Ecosystem modeling would establish carbon storage in the 

absence of positive or negative leakage and may have lower uncertainty – especially for logging residue 
36

– than the estimate with leakage. Appendix D depicts three biological scenarios for the total carbon 

storage in a forest system, including live, dead, and soil stores of carbon. Graphically, Figure D-2 in 

Appendix D shows how the storage of carbon in a forest system could respond to a shorter harvest 

interval. Note that all graphs in Appendix D show the biological response and do not account for 

management changes that could be induced through markets or policies. 

Modeling physical land carbon responses over time (without market effects) would show how carbon 

storage varies by such factors as length of harvest rotations, initial stand age and density, thinning 

fraction, and growth rates. These carbon responses to management decisions are important inputs for 

economic modeling of management changes and their carbon consequences. Such modeling could also 

include the effect of avoided fire emissions on forest land due to biomass removal. This information 

could indicate what forest conditions and practices could provide higher rates of accumulation, 

information that might be helpful for EPA in designing its policy response so that incentives could be 

provided to favor harvest in areas with a higher likelihood of carbon accumulation. 

Question 4(g). Are there additional limitations of the accounting framework itself that should be 

considered? 

A number of important limitations of the Framework are discussed below: 

Framework ambiguity: Key Framework features were left unresolved, such as the selection of regional 

boundaries (the methods for determining as well as implications), marginal versus average accounting, 

inclusion of working or non-working lands in the region when measuring changes in forest carbon 

stocks, inclusion/exclusion of leakage, and specific data sources for implementation. As a result, the 

Framework’s implementation remains ambiguous. The ambiguity and uncertainty in the text regarding 

what are stable elements versus actual proposals also clouded the evaluation. If the EPA is entertaining 

alternatives and would like the SAB to comment on alternatives, then the alternatives should be clearly 

articulated and the proposed Framework and case studies should be presented with alternative 

formulations to illustrate the implementation and implications of alternatives. 

Feedstock groups: The proposal designates three feedstock groupings. However, it is not clear what 

these mean for BAF calculations, if anything. The Framework does not incorporate the groupings into 

the details of the methodology or the case studies. As a result, it is currently impossible to evaluate their 

implications.

Potential for Unintended consequences: The proposed Framework is likely to create perverse incentives 

for investors and land-owners and result in unintended consequences. For investors, the regional 

baseline reference year approach will create regions that are one of two types — either able to support 

bioenergy from forest roundwood (up to the gain in carbon stock relative to the reference year), or not. 

As a result, a stationary source investor will only entertain keeping, improving, and building facilities 

using biomass from regions designated as able to support bioenergy. However, as noted previously, 

regions losing carbon relative to the reference year could actually gain carbon stock in relative terms due 

to improved biomass use and management to meet market demands. In addition, the definitions of 

regions would need to change over time. The designation of regions (and their corresponding LARs) that 

comes from the reference year approach will create economic rents and therefore financial stakes in the 

determination of regions and management of forests in those regions.
37

The proposed Framework could also create perverse incentives for landowners. For instance, 

landowners may be inclined to clear forest land a year or more in advance of growing and using energy 

crops. Similarly, landowners may be more inclined to use nitrogen fertilizers on feedstocks or other 

lands in conjunction with biomass production. Such fertilization practices have non-CO2 greenhouse gas 

consequences (specifically N2O emissions) that are not presently captured by the Framework. It should 

be noted that agricultural intensification of production via fertilization is a possible response to increased 

demand for biomass for energy. If onsite N2O emissions are not accounted for, the carbon footprint of 

agricultural feedstocks could be significantly underestimated. 

Assessment of Monitoring and Estimation Approaches: The Framework lacks a scientific assessment of 

different monitoring/estimation approaches and their uncertainty. This is a critical omission as it is 

essential to have a good understanding of the technical basis and uncertainty underlying the use of 

existing data, models and look-up tables. A review of monitoring and verification for carbon emissions 

from different countries, both from fossil and biogenic sources, was recently released by the National 

Research Council (National Research Council 2010). This review may provide some guidance.
38

3.5. Case Studies

Charge Question 5: EPA presents a series of case studies in the Appendix of the report to 

demonstrate how the accounting framework addresses a diverse set of circumstances in which 

stationary sources emit biogenic CO2 emissions. Three charge questions are proposed by EPA.

Overall Comments

In general, case studies are extremely valuable for informing the reader with examples of how the 

Framework would apply for specific cases. While they illustrate the manner in which a BAF is 

calculated, the data inputs are illustrative only and may or may not be the appropriate values for an 

actual biomass-to-energy project. Moreover, the case studies are simplistic relative to the manner in 

which biomass is converted to energy in the real world. For all case studies in the Framework, additional 

definition of the context is needed, along with examples of how the data are collected or measured, and a 

discussion of the impacts of data uncertainty. Overall, the case studies did not fully cover the relevant 

variation in feedstocks, facilities, regions, etc. of potential BAFs that is required to evaluate the 

methodology. For clarity, it might be useful to start with a specific forestry or agricultural feedstock 

example as the base case, then add the impacts of the more detailed cases, e.g., additional losses, 

products, land use changes. 

Question 5(a). Does the SAB consider these case studies to be appropriate and realistic? 

The case studies did not incorporate “real-world” scenarios which would have served as models for 

other situations that may involve biogenic carbon emissions. More would have been learned about the 

proposed Framework by testing it in multiple, unique case studies with more realistic data development 

and inclusion. Additional case studies for landfills and waste combustion, switchgrass, waste, and other 

regions would be useful, as well as illustrations of the implementation of feedstock groups, and 

Framework alternatives.

For example, Case Study 4 considers a scenario where corn stover is used for generating electricity. 

While it is possible that this scenario could be implemented, this particular case study is not realistic 

because very few electrical generation facilities would combust corn stover or agricultural crop residues

only. A more likely scenario might be supplementing a co-firing facility with a low percentage of corn 

stover. Additionally, the assumption of uniform corn stover yields across the region is not realistic. 

Variation should be expected in the yield of corn stover across the region.

In another example, Case Study 5 calculates the net biogenic emissions from converting agricultural 

land in row crops to poplar for electricity production. This case study is also not representative of “real 

world” agricultural conditions as switching from one energy crop to another is uncommon. The formula 

provided for estimating the standing stock of carbon in the aboveground biomass in the poplar system is 

not intuitive. The methods for determining biomass yield and measuring changes in soil carbon (which 

will depend on current use of the land) are not described. 
39

Question 5(b). Does the EPA provide sufficient information to support how EPA has applied the 

accounting framework in each case? 

There remained considerable uncertainty in many of the inputs. In addition, some sensitivity/uncertainty 

analysis would be useful. The results of this analysis may guide the EPA in further model development. 

For example, if the BAF is determined to be zero, or not statistically different from zero, in most case 

studies, then this could pave the way for a simpler framework. As discussed in Section 4 below, a

simpler approach could be designed to develop default BAFs for categories of feedstocks based on how 

their management and use interacts with the carbon cycle.

Question 5(c). Are there alternative approaches or case studies that EPA should consider to 

illustrate more effectively how the framework is applied to stationary sources?

Additional case studies should be designed based on actual or proposed biomass to energy projects to 

capture realistic situations of biomass development, production and utilization. For example, Case Study 

1 describes the construction of one new plant. What would happen if 10 new plants were to be proposed 

for a region? And how would the introduction of multiple facilities at the same time impact the 

accounting for each facility? 

All terms/values used to determine the BAF need to be referenced to actual conditions throughout the 

growth/production/generation processes that would occur in each case study. This should include an 

indication of how these values would actually be implemented by one or more involved parties. 

Regional look-up tables could be valuable and EPA could learn a great deal by trying to develop look-up 

tables. 

Additional case studies could be developed for perennial herbaceous energy crops, annual 

energy/biomass sorghums, rotations with food and energy crops, cropping systems on different land and 

soil types, municipal solid waste and internal reuse of process materials. Each of these feedstocks should 

be assessed across alternative regions so that the variation in carbon changes across regions could be 

gauged. 

For example it would be very useful to consider the application of the Framework to a cellulosic ethanol 

plant fueled with coal or gas, and consider the emissions of CO2 from fermentation (not combustion) 

and the production of ethanol which is rapidly combusted to CO2 in a non-stationary engine. While such 

an operation is associated with three major sources of CO2 emissions (listed here), only one is included 

in the Framework; only two may be considered under EPA’s regulatory authority, yet all three are 

emissions to the atmosphere. It would be useful for EPA to at least describe the emissions that are 

excluded from consideration so that biogenic carbon emissions from stationary sources can be viewed in 

context. 

At least two case studies are needed on municipal solid waste. One case study should be on waste 

combustion with electrical energy recovery. EPA should also perform a case study on landfill disposal 

of municipal solid waste. Here it is important to recognize that landfills are repositories of biogenic 

organic carbon in the form of lignocellulosic substrates (e.g., paper made from mechanical pulp, yard 

waste, food waste). There is literature to document carbon storage and the EPA has recognized carbon 

storage in previous greenhouse gas assessments of municipal solid waste management. 
40

In Case Study 3 the data used in Table 3 to describe the ‘paper co-product’ will vary with the grade of 

paper. The ‘carbon content of product’ may vary between 30 to 50% depending on the grade and the 

amount of fillers and additives. Also, some significant carbon streams in a mill can go to landfills and 

waste water treatment. The submitted comments from the National Council for Air and Stream 

Improvement (NCASI) include a useful example of the detail/clarity that could be used to enhance the 

value of the Case Studies.

After completion of the case studies, a formal evaluation would be useful to gauge the ease with which 

data were developed and the model implemented, whether the results are robust and useful in 

recognition of the uncertainty in the various input parameters, and whether the model results lead to 

unintended consequences. 

Case studies could be developed to assess and develop a list of feedstocks or applications that could be 

excluded from accounting requirements as “anyway” emissions. A sensitivity analysis using case studies 

could be used to develop reasonable offset adjustment factors if they are needed to adjust “anyway”

feedstocks for impact on long term stocks like soil if needed. 

3.6. Overall Evaluation

Charge Question 6: Overall, this report is the outcome of EPA’s analysis of the science and 

technical issues associated with accounting for biogenic CO2 emissions from stationary sources. 

Question 6(a). Does the report in total contribute usefully to advancement of understanding of 

accounting for biogenic CO2 emissions from stationary sources? 

Yes, the Framework is a step forward in advancing our understanding how to account for biogenic 

emissions. It addresses many issues that arise in such an accounting system and it is thoughtful and far 

reaching in the questions it tackles. Its main contribution is to force important questions and offer some 

ways to deal with these. It covers many of the complicated issues associated with the accounting of 

biogenic CO2 emissions from stationary sources and acknowledges that its choices will have 

implications for the estimates of CO2 emissions obtained. These include those raised by SAB and 

discussed above, related to the choice of baseline, region selection and the averaging of emissions/stocks 

over space and time. However, the solutions offered in many cases, particularly those related to the use 

of harvested wood for bioenergy, lack transparency or a scientific justification. 

Question 6(b). Does it provide a mechanism for stationary sources to adjust their total onsite 

emissions on the basis of the carbon cycle? 

Clearly the Framework offers a mechanism to adjust total on-site emissions. For short accumulation

feedstocks (i.e., agricultural residues, perennial herbaceous crops, mill wood wastes, other wastes), the 

Framework could, with some modifications and careful consideration of data and implementation, 

accurately represent the direct carbon changes offsite. Leakage, however, both positive and negative, 

remains a troublesome matter if left unresolved. Moreover, the Framework offers no scientifically sound

way to define a region. The definition of the regional scale can make a large difference to the estimate of 

emissions from a facility using wood as a biomass. Moreover, if there is no connection between actions 

of the point source and what happens in the region, there is no foundation for using regional changes in 

carbon stocks to assign a BAF to the source.
41

The Framework also does not make a clear scientific case for use of waste or what is called “anyway” 

emissions. Scientifically speaking, all biogenic emissions are “anyway” emissions. Even most woody 

biomass harvested from old growth forests, would, if left undisturbed, eventually die and decompose, 

returning carbon to the atmosphere. The appropriate distinction is not whether the product is waste or 

will eventually end up in the atmosphere anyway, but whether the stationary source is leading to an 

increase or a decrease in biogenic carbon stocks and associated change in Global Warming Potential 

(GWP). To do this, the Framework must consider an anticipated baseline and the time period for 

“anyway” emissions and that this may vary across different types of waste feedstocks. 

An important limitation of the proposed Framework is that the accounting system replaces space for 

time and applies responsibility for things that happen on the land to a point source, for which the agent 

who owns that point source has no direct control. Rather than comparing a “with” and “without” 

bioenergy scenarios over time, the Framework is based on spatial regions The proposed approach, which 

attempts to estimate facility-feedstock specific BAFs, would estimate an individual point source’s BAF 

based on average data in a region in which it is located. Any biogenic carbon accounting system that 

attempts to create responsibility or give credit at a point source for carbon changes upstream or 

downstream from the point source must relate those responsibilities and credits to actions under control 

of the point source. However, the Framework does not clearly specify a cause and effect relationship 

between a facility and the biogenic CO2 emissions attributed to it. In particular, if the BAF is assigned to 

a plant when it is approved for construction, as the BAF is currently designed, those emissions related to 

land use change will have nothing to do with the actual effect of the point source on land use emissions 

because the data on which it is based would predate the operation of the plant.

The dynamics of carbon accumulation in vegetation and soils and carbon and methane release through

decomposition present a challenge for any accounting system because anticipated future changes in 

vegetation should, in principle, be factored into BAF. These future changes depend on natural processes 

such as fires and pest outbreaks that are not easily foreseen, and because of climate change and broader 

environmental change, we face a system that is hard to predict. Projecting forward based on current or 

historical patterns is subject to biases of unknown direction and magnitude. More importantly, land use 

decisions are under the control of landowners, who will be responding to unknown future events. The 

Framework recognizes this issue and chooses to use a Reference Point Baseline, the serious limitations 

of which have been discussed previously.

Overall, the EPA’s regulatory boundaries, and hence the Framework, are in conflict with a more 

comprehensive carbon accounting that considers the entire carbon cycle and the possibility of gains from 

trade between sources, among sources or between sources and sinks to offset fossil fuel combustion 

emissions. Scientifically, a comprehensive greenhouse gas accounting would extend downstream – to 

emissions from by-products, co-products or products such as ethanol combustion or ethanol by-products 

such as distillers dried grains that are sold as livestock feed that ultimately becomes CO2 (or CH4). 

However, such a comprehensive accounting would require consideration of consistency with fossil fuel 

emissions accounting and emissions currently regulated (such as by EPA with vehicle greenhouse 

emissions standards). As for gains from trade, by restricting its attention to the regulation of point source 

emissions, EPA’s analysis does not allow for the possibility that a fossil CO2 emitter could contract with 

land owners to offset their emissions through forest protection and regrowth or carbon accumulation in 

soils. Bioenergy would still need to confront the issue of crediting offset carbon accumulation however. 

By staying within boundaries drawn narrowly around the stationary source, the Framework eclipses a 

more comprehensive approach to greenhouse gas reductions that would address all sources and sinks 

and take advantage of gains from trade. 
42

Question 6(c). Does the SAB have any advice regarding potential revisions that might enhance the 

final document?

Overall, the Framework would be enhanced by including a description of its regulatory context and 

specifying the boundaries for regulating upstream and downstream emissions while implementing the 

regulation. The motivation for the Framework should be explained as it relates to Clean Air Act 

requirements and any recent court rulings. The Framework should also make explicit the constraints 

within which greenhouse gases can be regulated under the Clean Air Act. In doing this, the EPA could 

be clear that these issues have not been settled but that some assumptions were necessary to make a 

decision about the Framework. The EPA could also stipulate that further development of a regulatory 

structure might require changes to the accounting system. While the SAB understands the EPA’s interest 

in describing an accounting system as a first step and potentially independent of the regulatory structure, 

the reader needs this background in order to understand the boundaries and context for the accounting 

structure and to evaluate the scientific integrity of the approach.

Similarly, the Framework is mostly silent on how possible regulatory measures under the Clean Air Act 

may relate to other policies that affect land use changes or the combustion/oxidation of products from 

the point sources that will release carbon or other greenhouse gases. For example if a regulatory or 

incentive system exists to provide credits for carbon offsets through land use management then under 

some conditions it would be appropriate to assign a BAF of 1 to biogenic emissions given that the 

carbon consequences were addressed through other policies. 

The Framework does not make explicit how it does or does not address emissions downstream from a 

point source such as in the case of a biofuels or paper production facility where the product (biofuels, 

paper) may lead to CO2 emissions when the biofuels are combusted or the paper disposed of and 

possibly incinerated. For example, if paper products are incinerated the incinerator may well be a point 

source that comes under Clean Air Act regulation. However, biofuels used in vehicles would not be 

subject to regulation as a point source. Though biofuel combustion emissions are already regulated, 

along with combustion of gasoline, via EPA’s vehicle greenhouse gas emissions standards, the EPA

needs to make clear the implicit assumptions on how biogenic carbon will be treated upstream and 

downstream from the point source if this Framework is used to regulate CO2 emissions under the

constraints imposed by the Clean Air Act for regulating stationary sources.

The Framework is lacking in implementation details. Implementation is crucial and some of the EPA’s 

current proposals will be difficult to implement. Data availability and quality, as well as procedural 

details (e.g., application process, calculation frequency) are important considerations for assessing the 

feasibility of implementation and scientific accuracy of results. Implementation details (e.g., data, 

technical processes, administrative procedures, timing) need to be laid out, discussed and justified. 

Among other things, the discussion should note alternatives, uncertainty and implications via case 

studies. 

Recommendations for Revising BAF

In response to the charge to the SAB, recommendations are offered here for revising the Framework. In 

the next section, the SAB suggests an alternative – default BAFs. If EPA decides to revise the 

Framework, the following recommendations for specific improvements to the document (and 

methodology) are summarized here. Many of the issues raised in previous responses regarding the 
43

treatment of specific factors included in the Framework are specific to particular feedstocks. The clarity 

of the Framework would be improved by differentiating among feedstocks based on how their 

management and use interacts with the carbon cycle. A BAF equation could be developed for each of 

these categories of feedstocks. 

If EPA decides to revise the Framework, the following recommendations for specific improvements are 

summarized below. 

Develop a separate BAF equation for each feedstock category as broadly categorized by type, 

region, prior land use and current management practices. Feedstocks could be categorized into short 

rotation dedicated energy crops, crop residues, forest residues, perennial crops, municipal solid 

waste, long rotation trees and waste materials including wood mill residue and pulping liquor. They 

could be differentiated based on different prior land uses and different management practices. 

o For long-accumulation feedstocks like woody biomass, use an anticipated baseline and landscape 

approach to compare emissions from increased biomass harvesting against a baseline without 

increased biomass demand. For long rotation woody biomass, sophisticated modeling is needed 

to capture the complex interaction between electricity generating facilities and forest markets, in 

particular, market driven shifts in planting, management and harvests, induced displacement of 

existing uses of biomass, land use changes, including interactions between agriculture and forests 

and the relative contribution of different feedstock source categories (logging residuals, 

pulpwood or roundwood harvest).

o For residues, consider incorporating information about decay after an appropriate analysis in 

which storage of ecosystem carbon is calculated based on decay functions. 

o For materials diverted from the waste stream, consider their alternate fate, whether they might 

decompose over a long period of time, whether they would be deposited in anaerobic landfills, 

and whether they are diverted from recycling and reuse, etc. Implementation complexity, cost 

and scientific accuracy should be considered. For feedstocks that are found to have relatively 

minor impacts, the EPA may need to weigh ease of implementation against scientific accuracy. 

After calculating decay rates and considering alternate fates, EPA may wish to declare certain 

categories of feedstocks with relatively low impacts as having a very low BAF or setting it to 0. 

Incorporate various time scales and consider the tradeoffs in choosing between different time scales. 

For all feedstocks, consider information about carbon leakage to determine its directionality as well 

as leakage into other media. 
44

4. DEFAULT BAFs BASED ON FEEDSTOCK CATEGORIES

There are no easy answers to accounting for the greenhouse gas implications of bioenergy. Given the 

uncertainties, technical difficulties and implementation challenges associated with implementing the 

facility-specific BAF approach embodied in the Framework, the SAB encourages the EPA to “think 

outside the box” and look at alternatives to the Framework and its implementation as proposed. One 

promising alternative is default BAFs for each feedstock category. Given the daunting technical 

challenges of the Framework, and the prospective difficulties with implementation, the SAB 

recommends consideration of default BAFs by feedstock type, region, land management and prior land 

use. Under EPA’s Framework, facilities would use individual BAFs designed to capture the incremental 

carbon cycle and net emissions effects of their use of a biogenic feedstock. With default BAFs, facilities 

would use a weighted combination of default BAFs relevant to their feedstock consumption and 

location. 

The defaults BAFs would rely on readily available data and reflect landscape and aggregate demand 

effects, including previous land use. The defaults would also have administrative advantages in that they 

would be easier to implement and update. Default BAFs for each category of feedstocks would 

differentiate among feedstocks using general information on their role in the carbon cycle. An 

anticipated baseline would allow for consideration of prior land use, management, alternate fate (what 

would happen to the feedstock if not combusted for energy) and regional differences. Default BAFs 

might vary by region, prior land use and current land management practices due to differences these 

might cause in the interaction between feedstock production and the carbon cycle. They would be 

applied by stationary facilities to determine their quantity of biogenic emissions that would be subject to 

the agency’s Tailoring Rule. Case studies should be used to evaluate the applicability of default BAFs 

to heterogeneous facilities. Facilities could also be given the option of demonstrating a lower BAF for 

the feedstock they are using. This would be facilitated by making the BAF calculation transparent and 

based on data readily available to facilities. Default BAFs should be carefully designed to provide 

incentives to facilities to choose feedstocks with the lower greenhouse gas impacts. 

The SAB also explored certification systems as a possible way to obviate the need to quantify a specific 

net change in greenhouse gases associated with a particular stationary facility. Carbon accounting 

registries have been developed to account for and certify CO2 emissions reductions and sequestration 

from changes in forest management. Ultimately, however, the SAB concluded that it could not 

recommend certification without further evaluation. Moreover, such systems could encounter many of 

the same data, scientific and implementation problems that bedevil the Framework. 
45

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A-1

APPENDIX A: Charge to the Panel

MEMORANDUM

To: Holly Stallworth, DFO

Science Advisory Board Staff Office

From: Paul Gunning, Acting Director 

Climate Change Division

Subject: Accounting Framework for Biogenic Carbon Dioxide (CO2) Emissions from 

Stationary Sources and Charge Questions for SAB peer review

The purpose of this memorandum is to transmit the draft Accounting Framework for Biogenic 

CO2 Emissions study and the charge questions for consideration by the Science Advisory Board 

(SAB) during your upcoming peer review in fall 2011. 

In January 2011, the U.S. Environmental Protection Agency (EPA) announced a series of steps it 

would take to address biogenic CO2 emissions from stationary sources. In addition to specific 

regulatory action, EPA committed to conduct a detailed examination of the science and technical 

issues related to accounting for biogenic CO2 emissions and to develop an accounting framework 

for those emissions. The study transmitted today is that examination. 

The study identifies key scientific and technical factors that should be considered when 

constructing any framework for accounting for the impact of utilizing biologically-based 

feedstocks at stationary sources. It then provides EPA’s recommendations on those issues and 

presents a framework for “adjusting” estimates of onsite biogenic CO2 emissions (i.e., a 

“biogenic accounting factor” or BAF) on the basis of information about the carbon cycle. 

As indicated in the accompanying materials, advice on these issues will be important as EPA

moves through the steps to address biogenic CO2 emissions from stationary sources. We look 

forward to the SAB’s review.

Please contact me if you have any questions about the attached study and charge.
A-2

Charge Questions

EPA is providing this study, Accounting Framework for Biogenic CO2 Emissions from 

Stationary Sources (September 15, 2011), to the Science Advisory Board (SAB) to review 

EPA’s approach on accounting for biogenic CO2 emissions from stationary sources, including 

the scientific basis and methodological components necessary to complete that accounting. 

Objective

EPA is charging the SAB to review and comment on (1) EPA’s characterization of the science 

and technical issues relevant to accounting for biogenic CO2 emissions from stationary sources; 

(2) EPA’s framework, overall approach, and methodological choices for accounting for these 

emissions; and (3) options for improving upon the framework for accounting for biogenic CO2

emissions. 

This charge does not ask the SAB for regulatory recommendations or legal interpretation of the 

Clean Air Act statutes related to stationary sources.

Charge Questions

1. Evaluation of the science of biogenic CO2 emissions

In reviewing the scientific literature on biogenic CO2 emissions, EPA assessed the underlying 

science of the carbon cycle, characterized fossil and biogenic carbon reservoirs, and discussed 

the implications for biogenic CO2 accounting. Does the SAB support EPA’s assessment and 

characterization of the underlying science and the implications for biogenic CO2 accounting?

2. Evaluation of biogenic CO2 accounting approaches 

In this report, EPA considered existing accounting approaches in terms of their ability to reflect 

the underlying science of the carbon cycle and also evaluated these approaches on whether or not 

they could be readily and rigorously applied in a stationary source context in which onsite 

emissions are the primary focus. On the basis of these considerations, EPA concluded that a new 

accounting framework is needed for stationary sources.

2(a). Does the SAB agree with EPA’s concerns about applying the IPCC national approach 

to biogenic CO2 emissions at individual stationary sources?

2(b). Does the SAB support the conclusion that the categorical approaches (inclusion and 

exclusion) are inappropriate for this purpose, based on the characteristics of the carbon 

cycle? 

2(c). Does the SAB support EPA’s conclusion that a new framework is needed for situations 

in which only onsite emissions are considered for non-biologically-based (i.e., fossil) 

feedstocks?

2(d). Are there additional accounting approaches that could be applied in the context of 

biogenic CO2 emissions from stationary sources that should have been evaluated but 

were not? 
A-3

3. Evaluation of methodological issues 

EPA identified and evaluated a series of factors in addition to direct biogenic CO2 emissions 

from a stationary source that may influence the changes in carbon stocks that occur offsite, 

beyond the stationary source (e.g., changes in carbon stocks, emissions due to land-use and land 

management change, temporal and spatial scales, feedstock categorization) that are related to the 

carbon cycle and should be considered when developing a framework to adjust total onsite 

emissions from a stationary source. 

3(a). Does SAB support EPA’s conclusions on how these factors should be included in 

accounting for biogenic CO2 emissions, taking into consideration recent advances and 

studies relevant to biogenic CO2 accounting? 

3(b). Does SAB support EPA’s distinction between policy and technical considerations 

concerning the treatment of specific factors in an accounting approach? 

3(c). Are there additional factors that EPA should include in its assessment? If so, please 

specify those factors.

3(d). Should any factors be modified or eliminated? 

4. Evaluation of accounting framework

EPA's accounting framework is intended to be broadly applicable to situations in which there is a 

need to represent the changes in carbon stocks that occur offsite, beyond the stationary source, or 

in other words, to develop a “biogenic accounting factor” (BAF) for biogenic CO2 emissions 

from stationary sources.

4(a). Does the framework accurately represent the changes in carbon stocks that occur 

offsite, beyond the stationary source (i.e., the BAF)? 

4(b). Is it scientifically rigorous?

4(c). Does it utilize existing data sources?

4(d). Is it easily updated as new data become available?

4(e). Is it simple to implement and understand?

4(f). Can the SAB recommend improvements to the framework to address the issue of 

attribution of changes in land-based carbon stocks? 

4(g). Are there additional limitations of the accounting framework itself that should be 

considered?

5. Evaluation of and recommendations on case studies 

EPA presents a series of case studies in the Appendix to demonstrate how the accounting 

framework addresses a diverse set of circumstances in which stationary sources emit biogenic 

CO2 emissions. 

5(a). Does the SAB consider these case studies to be appropriate and realistic? 

5(b). Does the EPA provide sufficient information to support how EPA has applied the 

accounting framework in each case? 

5(c). Are there alternative approaches or case studies that EPA should consider to illustrate 

more effectively how the framework is applied to stationary sources?

6. Overall evaluation
A-4

Overall, this report is the outcome of EPA’s analysis of the science and technical issues 

associated with accounting for biogenic CO2 emissions from stationary sources. 

6(a). Does the report – in total – contribute usefully to the advancement of understanding on 

accounting for biogenic CO2 emissions from stationary source?

6(b). Does it provide a mechanism for stationary sources to adjust their total onsite emissions 

on the basis of the carbon cycle? 

6(c). Does the SAB have advice regarding potential revisions to this draft study that might 

enhance the utility of the final document?
B-1

APPENDIX B: Temporal Changes in Stand Level Biogenic Emissions Versus Fossil 

Emissions

Cherubini et al. (2011) analyzes temperature increases on the basis of GWP (global warming potential) 

whereas Cherubini et al. (2012) analyzes climate impacts using GTP (global temperature potential). 

GWP is the time integral of the change in radiative forcing from a pulse emission of CO2 (in this case, 

from harvested biomass) and subsequent sequestration by biomass growth, whereas GTP is the integral 

of actual temperature response to a pulse emission of CO2 and subsequent sequestration by biomass 

growth. Both studies use a simple contrived comparison of biogenic emissions from a single stand over 

hundreds of years to comparable fossil emissions. Much is assumed regarding for instance global 

activity and emissions, and climate and carbon cycle dynamics. Also, importantly, landscape responses 

and investment behavior are not reflected which represent concurrent and related emissions and 

sequestration that affect net global emissions changes. 

Both studies incorporate a suite of carbon uptake mechanisms (such as oceanic uptake) in addition to 

regrowth in forest stands. In this context, the GTPbio, discussed by Cherubini (2012), is a more accurate 

metric for the actual climate response. The idea of the GTPbio is simple: it represents the increase in 

global average temperature over a given period due to a transient increase in carbon dioxide in the 

atmosphere (between the initial biomass combustion or respiration and the ultimate regrowth of the 

carbon stock) relative to the temperature response to a release of an equivalent amount of fossil CO2 at 

time 0 (expressed as a fraction between 0 and 1). To calculate a GTPbio value, a time scale must be 

specified. The calculation for GTPbio is the ratio of the average temperature increase with biogenic 

emissions followed by reabsorbtion by biomass regrowth over, say, 100 years divided by the average

temperature increase from the initial emission alone over 100 years. For short accumulation feedstocks, 

such as perennial grasses, GTPbio would be a very small fraction due to fast carbon accumulation times 

(ignoring leakage effects). For feedstocks with long accumulation times, one must compute the change 

in global temperature over time, accounting for the decline in temperature change as carbon is 

reabsorbed. 

Cherubini et al. (2011, 2012) provide an artificial simplified example for a single forest stand. The same 

type of metric could be used to compare temperature changes or changes in radiative forcing associated 

with increased biomass energy use for one year or more for a landscape or nation – taking into account 

the land carbon change over time associated with increased biomass energy use. This would involve 

comparison of a business as usual case to an increased biomass use case. A simpler metric that compares 

the cumulative radiative forcing of biogenic feedstocks to the cumulative radiative forcing of fossil fuels 

over time could also be used, e.g.. Cherubini’s GWPbio. However the broader literature should be 

considered regarding the climate implications of alternative emissions pathways (see charge question 1 

response) while considering uncertainty in global emissions, climate response and the carbon cycle. 

Figure B-1 demonstrates the importance of the time horizon or, more specifically, the weight to place on 

temperature increases that occur in the short term versus temperature increases that occur later. Consider 

a scenario in which biomass is harvested, but the carbon stock is replaced within a 100 year time scale. 

The GTPbio for a 100-year regrowth and a 100 year time horizon is roughly 0.5, meaning that the timeintegrated global average temperature increase within that 100 year period is 50% of the temperature 

increase caused by an equivalent amount of fossil carbon (or straight CO2 release without regrowth of 

biomass). However, using the average temperature increase for the biogenic case over 100 years masks 

the fact that although there will be an initial increase in temperature near the beginning of the 100 year 
B-2

period the reabsorption of carbon in the forest will bring the effect on ground temperature to nearly zero 

by year 100, giving an average temperature that was 50% of the average fossil temperature increase over 

100 years. In fact the instantaneous temperature change for the biogenic case falls below zero slightly 

before 100 years because oceans initial absorb extra CO2 in response to the initial biogenic emission (see 

Figure B-1, adapted from Cherubini 2012, Figure 5a). The temperature effect equilibrates to zero as the 

ocean CO2 is balanced. A more precise picture of intertemporal effects is shown in Figure B-1, adapted 

from Cherubini et al. (2012). 

Figure B-1: Surface temperature change from biogenic emissions versus fossil fuel over time. Adapted from 

Cherubini et al. (2012) and reprinted with copyright permission. 

Cherubini et al. (2012) have shown that if biomass is harvested and the carbon is reabsorbed within a 

100 year time scale, the global average temperature increase over that 100 year period is 50% of the 

temperature increase caused by an equivalent amount of fossil carbon. We might conclude that biogenic 

emissions are roughly 50% as damaging as fossil fuels, however the high point of temperature increase 

created by biogenic emissions occurs early in the 100 year cycle and is back to zero by the time the 

carbon is reabsorbed. For the case where carbon is recovered within 100 years Cherubini et al. (2012) 

have shown that at 20 years, the average temperature increase (over 20 years) from biogenic fuel is 97% 

of the temperature increase caused by an equivalent amount of fossil carbon; for years 21 to 100 years, 

the average increased is 0.37 and for years 101 to 500, the increase is 0.02. 

A current practice for international reporting under IPCC guidelines and international treaty negotiations 

is to use greenhouse gas emissions and sink values that represent the cumulative radiative forcing for 

greenhouse gases over a 100 year period with uniform weighting over 100 years. Greenhouse gas values 
B-3

are reported in tons CO2 equivalent where one ton of CO2 equivalent is an index for the cumulative 

radiative forcing for a pulse emission of one ton of CO2 over 100 years. The CO2 equivalent for a ton of 

other greenhouse gases is given by how many times more radiative forcing it produces over 100 years 

compared to CO2 (e.g., 21 times for CH4) (EPA 2012).
C-1

APPENDIX C: Fate of Landscape Residue after Harvest and System Storage of 

Carbon

The decomposition of materials left after harvest can be estimated from the negative exponential decay 

equation (Olson 1963): Ct=C0 exp[-kt] where Ct=is the amount at any time t, C0 is the initial amount, k 

is the rate-constant of loss, and t is time. Solving this function for a range of rate-loss constants results in 

the relationship shown in Figure C-1 for a range of k that covers the most likely range for decomposition 

rates of leafy to woody material in North America. In no case does the store instantaneously drop to zero 

as assumed in the Framework. 

Figure C-1: Fate of residue/slash left after harvest as function of k and time since harvest.
C-2

The amount of carbon stored on average in a forest system or fuel-shed comprised of units or stands that 

generate equal amounts of residue or slash is given by: I/k, where I is the average forest input of residue 

or slash. To create a relative function independent of the amount of residue or slash created, the input of 

each harvest unit or stand can be set to either 1 (to give the proportion of the input) or 100 (to give a 

percent of the input). The average forest input (I) would therefore be equal to 1/RH or 100/ RH where RH

is the harvest return interval. Using this relationship to solve the average store relative to the input is 

presented in Figure C-2 for the most likely range of decomposition rates for leafy to woody material in 

North America. This indicates that there are a wide range of possible cases in which the store of residue 

or slash can exceed the initial input (shown by the horizontal line indicating storage of 1). This means 

that combusting this material will cause the store to drop by the amount indicated, and this amounts to 

the net flux of carbon to the atmosphere. To a large degree there is a negative relationship between the 

harvest interval and k; materials with high values of k (i.e., leafy) are typically harvested with short 

intervals between harvests and material with low values of k (i.e., large wood) are typically harvested 

with long interval between harvests. This suggests that the effect of harvesting residues and slash is 

largely independent of the loss rate-constant. 

Figure C-2: Landscape average store of residue/slash as function of k and harvest interval.
D-1

APPENDIX D: Carbon Balances over Time in an Existing Forest System

To determine whether a forest harvest system for existing forest acreage creates a carbon debt, or 

alternatively, a gain it is appropriate to examine this problem at the landscape-level (or in the context of 

biogenic carbon a fuel-shed basis). Note the discussion that follows refers only to existing managed 

forests (and their stored carbon) and not broader landscape effects such as the expansion or contraction 

of forest area. At the forest system level there are three possible cases: (1) a relatively constant, steadystate store of carbon if the harvest system is continued unchanged, (2) an increase of carbon stores to a 

higher steady state if the intensity of harvest declines, and (3) a decrease of carbon stores to a higher 

steady-state if the intensity of harvest increases. These cases are illustrated in Figures 4-6 which are 

based on the online Forest Sector Carbon Calculator used in the forest system landscape mode 

(http://landcarb.forestry.oregonstate.edu/default.aspx) . 

In Figure D-1, a 50-year clear-cut harvest rotation was practiced until 2010 and then continued for 500 

years. This resulted in no carbon debt. If tracked at the stand scale one would see carbon levels rising 

and falling, but over time the net balance is zero. In contrast, if one converted the 50-year clear-cut 

harvest rotation system to a 25-year clear-cut harvest rotation system as in Figure D-2 there would have 

been a decline in carbon stores in the ecosystem. This decline would be considered a carbon debt and 

while not permanent (i.e., forever), it would remain as long as the 25-year management system persists. 

If the 50-year clear-cut harvest rotation was replaced by a 100-year clear-cut system at year 2010, then 

there would have been a gain carbon stores (Figure D-3). That gain would remain as long as that 100-

year clear-cut system of management was maintained. All these simulations all assumed that soil 

productivity is maintained regardless of harvest interval. 

At the existing forest level (as opposed to the stand level), live, dead, and soil stores all acted the same. 

Each of these pools either remained in balance (i.e., no net gain) or could increase or decrease depending 

on how the interval of harvest changes. The steady-state store of all three pools is controlled by the I/k

relationship developed by Olson (1963), where I is the input of carbon to the pools and k is the 

proportion lost from the system in respiration and harvest (the live also has a loss related to mortality of 

trees). As the harvest interval decreases the input to the pool (I) decreases and the proportion lost via 

harvest (k) increases. This explains why the ecosystem stores decrease when the harvest interval is 

shortened and why they increase when the harvest interval is increased. A similar response happens 

when one takes a larger share of the carbon stores away when there is a harvest. 

These dynamics have several important implications that need to be considered in the context of 

biogenic carbon: (1) long-term carbon debts, gains, and balances are best examined at the forest systemlevel (not to mention the broader agriculture-forest landscape level), (2) all forest carbon pools can 

exhibit either debts, gains, or remain relatively constant, (3) most systems of forest management will 

reach a steady-state if maintained over a long enough period and this steady-state can be maintained as 

long as the management system is continued, and (4) ultimately reaching a steady-state does not 

determine if there has been a loss or gain in carbon as this depends on how harvest management changes 

from one steady-state to the next.
D-2

Figure D-1: Changes in carbon stores of major forest ecosystem pools when a 50 year clear-cut harvest system is 

established and continued. The result is a continued carbon balance.
D-3

Figure D-2: Changes in carbon stores of major forest ecosystem pools when a 50 year clear-cut harvest system is 

replaced by a 25 year clear-cut harvest system in 2010. The result is a carbon debt. 
D-4

Figure D-3: Changes in carbon stores of major forest ecosystem pools when a 50 year clear-cut harvest system is 

replaced by a 100 year clear-cut harvest system in 2010. The result is a carbon gain. 
E-1

APPENDIX E: Dissenting Opinion from Dr. Roger Sedjo

Introduction

EPA’s Science Advisory Board (SAB) was asked to review and comment on the EPA’s Accounting 

Framework for Biogenic CO2 Emissions from Stationary Sources (Framework September 2011). The 

motivation for the Accounting Framework “is whether and how to consider biogenic greenhouse gas 

emission in determining thresholds ... for Clean Air Act permitting” (p. 4). To my knowledge the SAB 

Advisory has been completed and is being submitted to the broader SAB process. The comments below 

(and page numbers cited) relate to the SAB Advisory draft of 6-15-12 (SAB 2012). 

I take fundamental issue with many of the elements of the SAB Report. Although I largely agree with 

the Advisory’s criticisms of the absence of supporting science for many of the Framework’s suggested 

approaches, I find unconvincing and unscientific much of the Advisory’s attempt to salvage large 

elements Framework’s approach. My comments focus largely, but not entirely, to forest issues in the 

Report not only because that is the area of my greatest expertise but also because the defects in the 

Framework approach are most egregious in forestry. 

The EPA considered whether to categorically include biogenic emission in its greenhouse gas 

accounting or whether to categorically exclude biogenic emissions (p 6-7). The agency rejected both 

extremes and asked the SAB whether it supported their conclusion that categorical approaches are 

inappropriate for treatment of biogenic carbon emissions. However, I do not believe that this issue was 

properly vetted within the SAB process. Although the statement that “carbon neutrality cannot be 

assumed for all biomass energy a priori” (p 7) is correct, it misrepresents the serious position developed 

by the Intergovernmental Panel on Climate Change (IPCC 2006) and commonly used included a critical 

qualification regarding the condition of land cover generally and forest stock specifically. This 

requirement is missing from the simplistic evaluation statement. This position is supported in the 

Appendix to this piece, (USDA appendix by Hohenstein, 2012), which notes that the major IPCC 

rationale does not claim “a priori” neutrality. The IPCC, which suggested this approach, makes carbon 

neutrality contingent on an aggregate monitoring approach that focuses on the changes in aggregate land 

use and forests. Thus, the definitive development of the wide spread exclusion of biogenic and wood 

does not, in fact, involve an a priori assumption of neutrality. Rather it involves a qualification (for 

wood) that the forest stock be constant or expanding. I should note here that consideration of that 

important qualification was largely absence from the evaluation by the SAB and, in my judgment, 

aggressively discouraged by the organizers from the SAB discussion.

Finally, if the proposed Accounting Framework were capable of providing reliable accounting, one 

might give it serious consideration as an alternative to the IPCC approach in achieving the EPA 

objectives. However, as is acknowledged by the Advisory (e.g., p. 15), the proposed Accounting 

Framework is replete with problems as are the calculations of the elements necessary for calculating the 

Biological Accounting Factor (BAF). The acknowledged scientific weaknesses in the EPA document are 

identified throughout the SAB Advisory.

This paper demonstrates below that the SAB Advisory has not adequately addressed some of these 

issues and has not found ways to estimate in a scientifically acceptable way the values of some of the 

requisite components of the BAF. 
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Defects in the Accounting Framework

Questions raised in the Advisory about the Framework run from the appropriateness of the proposed use 

of the same accounting framework for the various feedstocks, which are different, to issues dealing with 

the appropriate baseline and questions concerning the relevant timescale. The SAB Advisory essentially 

embraces a variant of the BAF approach, which was developed in the Framework, even though the 

Advisory points to numerous important weaknesses of the BAF approach. The BAF is a simple 

accounting model that tries to identify and measure the various components and impacts of carbon 

emissions and accumulations from biomass energy sources. Ultimately, the Advisory essentially 

embraces the general BAF approach but applies it differently to individual biogenic feedstocks. 

However, the Advisory acknowledges throughout that a number of the components of the BAF cannot 

be adequately measured. 

For example, the Advisory acknowledges that for important major elements of the Framework, e.g., 

leakage, there is no satisfactory monitoring or measurement system. Leakage, which can be either 

positive of negative, may involve the deflection of deforestation and associated emission out of 

woodshed under consideration or it may involve sequestration associated with offsetting forest 

management outside of that woodshed. Thus, the values of these major elements are essentially 

empirical, could be either positive or negative, but have their impacts outside of the area of direct 

observation. But, without accurate leakage values, the BAF approach proposed cannot accurately 

estimated for carbon changes. It cannot even determine the sign of the changes with any great accuracy. 

Thus, although the Advisory states that “it is important to have scientifically sound methods to account 

for greenhouse gas emission caused by human activities” (p 13), it acknowledges that the it is widely 

acknowledged in the literature that leakage cannot to be readily measured with any accuracy (Murray et 

al. 2004; Macauley et al. 2009). Nevertheless, in contradiction of this finding the Advisory suggests that 

“the agency ... try to ascertain the directionality of net leakage ... and incorporate that information into 

decision making.” (p 9-10). This suggestion flies in the face of the concept of “scientifically sound 

methods.” 

Indeed, the application of the proposed framework would either need to leave these elements of the BAF 

empty, as suggested in the USDA letter posted on the SAB website, or nonscientific guesses would need 

to be imposed, as suggested in parts of the Advisory. In either case large errors in measurement appear 

almost inevitable and, rather than providing the regulators with accurate information, would provide 

misinformation to regulators and would likely redound to errors in the application of regulations. The 

idea introduced in the Advisory of default BAFs does not do anything to address their fundamental lack 

of scientific rigor.

Other thorny issues involve questions of the boundaries of a woodshed and/or a region, which relate to 

the leakage question, the intermixing of industrial wood and biomass so that significant portions of any 

harvest are used for each, and the export of biomass for energy, e.g., the large flow of wood pellets to 

Europe, where their emissions for the production of bioenergy will not be captured in the accounting. 

Finally, any accounting approach that tries to monitor each biomass using unit is surely going to be time 

consuming and expensive, perhaps too expensive to justify the use of the biomass for energy (Sedjo and 

Sohngen 2012). 

An important defect is that the Advisory embraces a carbon-debt framework. However, this framework 

is an artifact of an arbitrary decision of how the accounting system is applied. If the forest is 

sustainability managed, then there is no carbon-debt. Withdrawals equal growth for both biomass and 
E-3

carbon. Accounting debts can occur in some circumstances, however. For a mature forest stand, if the 

accounting period begins with the harvest of the stand, as in the Manomet Study, a debt is incurred for 

that stand. Note that net carbon sequestration could be occurring in that forest but on different stands. 

Most forests are multi-aged and hence will have net growth occurring on some stands while stock 

reductions occur on other stands. 

An additional source of confusion regarding carbon debt is related to the accounting period. If the 

accounting focuses on a stand and the accounting period begins with the harvest, a debt will be 

establishment for the forest stand. However, if the accounting begins with the forest establishment, e.g., 

at tree planting, then the initial post planting growth is building up a stock of carbon that will be released 

at harvest. Thus, any future debt from that stand will have been offset in advance of the harvest and no 

intertemporal net carbon debt is incurred.

Thus, although an accounting debt can be found for mature stands, the debt is an artifact of the time 

period selected and the choice of how narrowly to define the relevant forest stands. Furthermore, a 

carbon debt will not be occurred for sustainably managed forests. In the aggregate, the U.S. forest 

system is more than sustainable as demonstrated by the FIA’s data going back to a least 1952. Thus, a 

fully accounting of the entire managed US forest does not find a carbon-debt.

In summary, the Advisory identifies a host of problems with the proposed Accounting Framework, and 

reports that “the SAB did not find the Framework to be scientifically rigorous” (p 30). Indeed, although 

the Framework is said to “include most of the elements that would be needed to gauge changes in CO2 

emissions,” the problems with the effective of monitoring, measurement and verification of several of 

the components are daunting. 

Alternative Approaches for Accounting for Biogenic Carbon

One wonders why the SAB exerted so much effort to try to save the Accounting Framework, containing 

as it does, such fundamental defects. It is my understanding that the SAB was asked to review and 

comment on the Framework, but not necessarily to save it. Indeed, as noted above, EPA’s change 

included the question of “whether ... to consider biogenic greenhouse gas emission in determining 

thresholds ... for Clean Air Act permitting” (p. 4).

Nevertheless, despite the identification of very serious defects in the approach, there is a considerable 

attempt in the SAB process to downplay the problems and ignore the lack of scientific bases for 

measuring some of the elements, apparently in order to preserve a variant of the approach, no matter 

how defective. 

There are at least two basic ways that one might approach the problem of estimating the net emissions 

associated with biogenic energy. The highly regarded scientific organization, Intergovernmental Panel 

on Climate Change (IPCC) has suggested an aggregate approach that would focus on the changes in 

aggregate land use and forests to determine whether, for example, aggregate forest stocks are expanding 

or contracting. This approach has been supported by the USDA (Hohenstein 2012) in a response to an 

earlier draft Advisory by the SAB.

In the context of measuring the total aggregate forest the issue of leakage and anticipatory management 

within the US does not arise since to total system is evaluated. Where the aggregate is subdivided into a 

few large international regions, these issues are more easily captured since flows in forest biomass are 
E-4

measured in the international trade statistics and individual woodshed monitoring is not necessary. 

Indeed, for the US this approach can easily be put in place at low cost since the Forest Service has been 

undertaking Forest Inventory Assessments (FIA) for over fifty years.

The alternative to the IPCC approach, suggested by the Accounting Framework, involves the individual 

audit of each separate woodshed associated with a facility and an attempt to estimate the impact of each 

individual operation on net emissions. Such an approach would be a monitoring nightmare complicated 

by the fact that wood feedstock could, and likely would on occasion, be brought into one region from 

other small regions as required, this situation would involve leakage. Leakage could be replete since 

more regions would almost surely involve more leakage. Not only is the individual wood shed audit 

approach much more expensive, it also is inadequate since wood sheds are not always well defined and 

wood will undoubtedly flow across various woodsheds and leakage will occur. However, such detail is 

entirely unnecessary for purposes of the broad monitoring of biogenic facilities and their effects on 

atmospheric carbon. The relevant consideration is not the infinitesimal impact of each individual 

facility. Rather, the concern is with the grand aggregate impact of the bioenergy system on net 

emissions. If this approach does not properly account for the effects of leakage and anticipatory forest 

management (reverse leakage), the BAF estimates will have basic errors.

The Framework approach and the SAB Advisory appear to accept the notion that the Framework 

Accounting approach is superior to the IPCC approach. However, no evidence of this is provided either 

in argumentation or in analytical studies. Nevertheless, it is probably indisputable that the costs of the 

Accounting Framework approach with its estimated BAFs are far higher than those associated with the 

IPCC approach. 

Five Summarizing Points

First, the guidelines provided by the EPA for the SAB Advisory essentially accept the Framework view 

and dismisses the IPCC suggested approach with regard to biogenic feedstocks within the land use 

sector, including forests. This was done despite that fact that there was no serious discussion by our 

SAB group of the adequacy or viability of the IPCC approach. Indeed the IPCC approach was dismissed 

by the EPA as inadequate on rather flimsy grounds. I note that my position is supported in the letter by 

William Hohenstein, Director of the Climate Change Program Office posted at the SAB website. The 

letter states that USDA “prefers the IPCC accounting framework” approach and takes issue with the 

rationale used by the SAB Advisory and its dismissal of the IPCC approached. USDA differs with the 

assertion of the SAB Advisory and maintains “the IPCC approach is not equivalent to an a priori 

assumption that these feedstocks are produced in a carbon neutral manner or an assertion that land use 

activities contributing feedstocks to the energy sector can be managed without consideration of 

atmospheric outcome.”

Second, an attempt to assess the carbon debt of individual stands fundamentally misses the point since it 

is the entire forest, not individual stands that are relevant to the carbon footprint as seen by the 

atmosphere. As such, the attempt to imperfectly apply the BAF to individual forests is costly and 

irrelevant to the aggregate U.S. carbon footprint. 

Third, although the Advisory acknowledges the dynamic nature of market driven supply systems that 

would be providing the biogenic energy feedstock, it essentially uses a static approach that largely 

ignores various market responses and adaptations to changing circumstances. Although the Advisory 

acknowledges that investment decisions for trees must predate their utilization by years and indeed 
E-5

decades, this reality is not incorporated into any BAF calculation. Indeed, while investment decisions 

must be driven by the anticipation of the existence and size of future markets, these considerations are 

acknowledged for wood biomass in parts of the Advisory and then disregarded in the application of the 

approach for regulatory purposes. Thus, the actual approach suggested is essentially static, missing the 

essential dynamic nature of the supply process. Despite these basic defects, the Advisory 

recommendations are treated as if they are scientifically sound. 

Fourth, the Advisory erroneously states that incentives for producing replacement bioenergy crops are 

absence. Such a result would occur in viable markets only if there were no anticipation of increasing 

future demand. However, a variety of signals, including requirements of renewal portfolio standards and 

forecasts of dramatic biomass energy demand increases over the next couple of decades by various 

authoritative organizations, e.g., EIA.

Fifth, the Advisory tends to support a very expensive and onerous regulatory accounting system rather 

than a much more efficient system such as suggested by the IPCC. This support is given without any 

apparent serious assessment or rationale that the regulatory results of the BAF system will be equal to or 

superior to those that would result from a much less expensive and less onerous IPCC type approach. 

In summary, I find that although the SAB Advisory provides a useful critique of the Accounting 

Framework and the BAF approach. However the Advisory falls into the trap of trying to make a 

basically defective system functional and tends to support many aspects of that flawed system. In the 

end the Advisory largely ignores its own criticisms and supports a fundamentally flawed approach. 

Thus, since the motivation for the Accounting Framework “is whether and how to consider biogenic 

greenhouse gas emission in determining thresholds ... for Clean Air Act permitting” (p. 4), it can 

rationally be concluded that biogenic greenhouse gas emission are best not considered in determining 

thresholds or perhaps considered only of the forest and land use conditions as such that they do not meet 

minimal IPCC conditions. 

References:

Hohenstein, William. 2012. Comments submitted to the EPA SRB regarding the Environmental 

Protection Agency’s draft Accounting Framework for Biogenic CO2 Emissions from Stationary 

Sources on behalf of USDA. May 25.

IPCC. 2006. Guidelines for National Greenhouse Gas Inventories: Agriculture, Forestry and Other Land 

Use Volume 4.

Macauley, Molly K., Daniel F. Morris, Roger A. Sedjo, Kate Farley, Brent L. Sohngen “Forest 

Measurement and Monitoring: Technical Capacity and “How Good Is Good Enough?” RFF 

Report | December 2009.

Murray, B.C.; McCarl, B.A.; Lee, H. (2004). Estimating Leakage from Forest Carbon Sequestration 

Programs. Land Economics, 109-124.

Sedjo, Roger and Brent Sohngen. 2012. “Carbon Sequestration in Forests and Soils,” in Annual Review 

of Resources Economics. 

SAB. 2012. 6-15-12 Deliberative Draft report of the Biogenic Carbon Emission Panel.