## Fw: Interagency revisions to EPA proposed Biogenic emissions language

Raj Rao to: Pam Long 08/10/2010 01:05 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 01:04 PM -----

From: "Kymn, Christine J." <Christine

_ J.

_ Kymn@omb.eop.gov>

To: Raj Rao/RTP/USEPA/US@EPA

Date: 08/03/2010 05:49 PM

Subject: RE: Interagency revisions to EPA proposed Biogenic emissions language



### -----Original Message-----

From: Rao.Raj@epamail.epa.gov [mailto:Rao.Raj@epamail.epa.gov]

Sent: Tuesday, August 03, 2010 2:57 PM

To: Kymn, Christine J.

Subject: Re: Interagency revisions to EPA proposed Biogenic emissions language

Hi Christine,

Thanks for these comments. We are reviewing and considering the edits and

will get back to you asap.

raj

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.

From: "Kymn, Christine J." <Christine_J._Kymn@omb.eop.gov>

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

Wood/DC/USEPA/US@EPA

Date: 08/03/2010 12:03 PM

Subject: Interagency revisions to EPA proposed Biogenic emissions

### language

Raj, Lisa, Anna,

Greetings. Attached please find proposed edits to EPA’s suggested biogenic

GHG language. Let’s chat sometime today about these if possible.

Thanks,

Christine

202.395.4638(See attached file: Interagency edits1_Proposed language, biogenic

GHG sources, EPA NPRMs, Actions to Ensure Authority to Issue Permits under the

PSD Program to Sources of GHG Emissions.docx)(See attached file: Interagency

edits2_Proposed language, biogenic GHG sources, EPA NPRMs, Actions to Ensure

Authority to Issue Permits under the PSD Program to Sources of GHG

Emissions.docx)

Interagency edits3_Proposed language, biogenic GHG sources, EPA NPRMs, Actions to Ensure Authority to Issue Permits under the P*** 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 greenhouse gases 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 program and Title V programs through future action, such as a

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

, we

are conducting a separate action to solicit public comment and data

on technical is s ues 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 Call for Information (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."

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

on the PSD applicability and public comments on our BACT guidance for biomass will inform the

subsequent actions to address applicability of emissions of greenhouse gases from bioenergy

and other biogenic sources under the PSD program.

*** For the FIP proposal, we could add this on p. 24, under "Recent EPA Regulatory Actions

Concerning PSD Requirements for GHG

‐ emitting Sources."



### In addition add to the FIP proposal: Deleted: Accordingly

Deleted: ¶

Deleted: the accounting and

other

Deleted: ¶

¶

Deleted: More specifically,

with¶

respect to PSD applicability

and BACT, EPA solicited

comment on what¶

criteria 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.

Deleted: ¶

Deleted: ¶

Deleted: ¶

### “...This rule specifies, in its applicability provis ions, the air pollutant subject to control as the

aggregate group of the six GHGs, including CO 2 

### , CH 4 

### , N 2 

### O, HFCs, PFCs, and SF 6 

### . 75 FR

25686 (40 CFR 86.1818-12(a)). 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 program and title V programs through a future action,

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

step, we are conducting a separate action 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 PS D 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 Call for Information (CFI) is available at

http://www.epa.gov/climatechange/emissions/bioge nic_emissions.html. In the CFI we stated:

"In response to this call for in formation, interested parties are invited to assist EPA in the

following way: (1) Surveying and assessing the sc ience 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 invite d to submit data or other relevant information about the current

and projected scope of GHG emissions from bioenergy and other biogenic sources."

We note that this issue warrants further explora tion in the BACT context as well. While we are

not promulgating an applicability exclusion for biogenic emissions and biomass fuels or

feedstocks at this time, there is flexibility to apply the existing regulati ons and policies regarding

BACT in ways that take into account their effe cts on GHG concentrations. This topic has been

explored by the CAAAC workgroup on BACT issues related to GHGs that recently provided

recommendations to EPA. These recommendations are located in the public docket at

http://www.epa.gov/air/caaac/climat e/2010_02_InterimPhaseIReport.pdf.

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

on the PSD applicability and public comments on our BACT guidance for biom ass will be useful to inform PSD

applicability, and if indicated, subs equent actions to address applicabi lity of emissions of greenhouse gases

from bioenergy and

other biogenic sources under the PSD program.

By notice dated April 2, 2010, EPA promulgated what is commonly known as the

Johnson Memo Reconsideration. ...” Comment [A1]: Please propose

another sentence.

Deleted: EPA notes that the LDVR

treats lifecycle CO2 emissions from¶

biomass differently than CO2 emissions

from conventional fuels. However, we

note that in this¶

rulemaking, we are not addressing the

issue of accounting for emissions of

greenhouse gases¶

from bioenergy and other biogenic

sources (which are generated during the

combustion or¶

decomposition of biologically based

material such as forest or agriculture

products).

Deleted: support¶