## Fw: biogenics

Raj Rao to: Pam Long 08/10/2010 01:07 PM



### Raj Rao, P.E.

Group Leader, NSRG

OAQPS/AQPD(MD- C504-03)

109 TW Alexander Drive

RTP, NC 27709

919-541-5344

919-541-5509 fax

Note: Positions or views expressed here do not represent official EPA policy. Interagency deliberative

and Confidential.

----- Forwarded by Raj Rao/RTP/USEPA/US on 08/10/2010 01:07 PM -----

From: "Kymn, Christine J." <Christine

_ J.

_ Kymn@omb.eop.gov>

To: Anna Wood/DC/USEPA/US@EPA, Raj Rao /RTP/USEPA/US@EPA, Lisa

Sutton/RTP/USEPA/US@EPA, Howard Hoffman/DC/USEPA/US@EPA, Paul

Balserak/DC/USEPA/US@EPA

Date: 08/05/2010 10:11 AM

Subject: biogenics



## Hi Folks,

I’ve had a chance to touch base with interagency reviewers on the biogenics language. I am sending

forward their redline edits, however, I would like for us to talk before you react with any counter

‐ edit.

Please call me as soon as possible so that we can discuss and hopefully resolve this language.

Thanks,

Christine

202.395.4638 Interagency4 on Final EPA language OfferCLEAN- 080410- Final.docx***For the SIP Call proposal, we could add this biomass CFI text on p. 51,

under "Definition and Calculation of Amount of GHGs."

We note that in this rulemaking, we are not addressing the issue of

accounting for emissions of GHGs from bioenergy and other

biogenic sources (which are generated during the combustion or

decomposition of biologically based material such as forest or

agriculture products). When we finalized the Tailoring Rule, we

noted that EPA planned to seek comment on how to address emissions of

biogenic CO2 under the PSD and title V programs through future action, such as a separate

Advance Notice of Proposed Rulemaking (ANPR) (75 FR at 31591). As a first step

, we recently

issued a Call for Information (CFI) to solicit public comment and data

on technical issues that might be used to consider biomass fuels and the emissions resulting

from their combustion differently with regard to applicability under PSD and with regard to

the BACT review process under PSD. See “Call for

Information: Information on Greenhouse Gas Emissions Associated with

Bioenergy and Other Biogenic Sources,” 75 FR 41173 (July 15, 2010).

Additional information on this CFI is available at

http://www.epa.gov/climatechange/emissions/biogenic_emissions.html

. In the CFI we stated:

"In response to this Call for Information,

interested parties are invited to assist EPA in the following way:

(1) Surveying and assessing the science by submitting research

studies or other relevant information, and

(2) evaluating different accounting approaches and options by providing policy

analyses,proposed or published methodologies, or other relevant information.

Interested parties are also invited to submit data or other relevant

information about the current and projected scope of GHG emissions

from bioenergy and other biogenic sources." 75 FR 41174

Without prejudging the outcome of that process, EPA anticipates that the comments we receive

in response to the CFI, with regard to applicability under PSD and with regard to the BACT

review process under PSD, will inform subsequent actions,

, to address applicability of

emissions of GHGs from bioenergy and other biogenic sources under the PSD program.

NOTE: EPA proposes to use the same language in both the SIP call and FIP proposals Deleted: Accordingly

Deleted: the CFI

Deleted: any

Deleted: as appropriate