***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).  AccordinglyAs a

first step, we  

are conducting a separate action to solicit public comment and data

on the accounting and other 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 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."   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.   

We note that this issue warrants further exploration 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 regulations and policies

regarding BACT in ways that take into account their effects 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/climate/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 biomass will inform support be

useful to inform PSD applicability, and if indicated, the development of

BACT guidance and the need to address applicability further in a

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:

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

aggregate group of the six GHGs, including CO2, CH4, N2O, HFCs, PFCs, and SF6. 75 FR

25686 (40 CFR 86.1818-12(a)). 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). 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 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."

We note that this issue warrants further exploration 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 regulations and policies regarding

BACT in ways that take into account their effects 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/climate/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 biomass will be useful to inform PSD 

applicability, and if indicated, support

subsequent actions to address applicability 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. ...”