From: "King, Heidi R." < Heidi_R._King@omb.eop.gov >

To: Suzanne Kocchi/DC/USEPA/US@EPA, Jennifer Jenkins/DC/USEPA/US@EPA

Date: 03/02/2011 12:01 PM Subject: Summary of interagency comments under EO12866 on Biomass

Deferral and Biomass BACT

Hello,

Attached is a summary of interagency comments received during EO12866 review.

More comments may be submitted cob today.

Best regards,

Heidi

(See attached file: Summary of Interagency Comments on EPA's GHG Biomass Deferral

and BACT Guidance.docx)Summary of Interagency Working Comments Submitted during EO 128 66 Review Subject to Further Policy Review

1) Could EPA confirm whether Peat (soil) is included in th e definition of a fuel?

2) A couple of comments on the rate of decomposition:

Some may disagree with the analysis that states “ utilizing mill residue (e.g. sawdust, planar shavings, panel trim) to generate energy, rather than leaving the residue to decompose, likely would not cause emissions over and above that which would have taken place if the energy use did not occur. Given that this material would have decomposed under natural circumstances in a short period of time (e.g., less than 10-15 years) in the absence of u tilization as bioenergy, this conclusion appears credible.”

In fact, federal fire agencies have experience wi th sawdust pile fires in the west that were 100 years old; On the whole this statement is true, if the time scale is adjusted to “10-100 years”, and that the proportion of the mill resi due that would fall outside the analysis, is insignificant.

o This sentence would also need to be corre cted to address the same time frame for decomposition... “Furthermore, in the cas e of residue material that would otherwise decompose in a 10-15 year time frame, the net carbon cycle impact of this biomass fuel is expected to be negligible.

I would add “wildfire” to this (?) section “generate energy from the combustion of dead trees, especially those killed due to a widespread event li ke the mountain pine beetle epidemic (that would emit CO 2 anyway through natural decomposition, “and wildfire”). This is the same issue as above. Dead timber in dry environments does not decompose on the time scaled implied or emit CO 2 solely through decomposition.

3) To avoid confusion, the word "current" should be placed before "biogenic source(s)." It

is critical to this whole is sue that "current biogenic carbon sources," such as perennial grasses, trees, manure, municipa l organics etc. be clearly separated from "prehistoric biogenic carbon sources," such as coal, pe troleum and underground natural gas. The

distinction between current and prehistoric is something that is prehistoric is generally considered 5000 or more years old. Given only a very few tree species that live for more than 5000 years, in general, any current biogenic source that is referred to in the deferral document is less than 5000 years old and is born and decomposed back into the carbon system within that time. As the document stands now coal, being "biogenic," I do not believe, is intended to be include d under this "deferra l." If the critical temporal distinction is not addressed, I anticipate continued conf usion and more insidiously, the ability to purposely misunderstand the true intention of the document.

4) As part of determining the amount and impact of CO 2 emissions - recommend that further research be conducted to determine the spec ific bulk density of biomass fuels and the

relative amount of CO 2 based on genus and species. Ther e is only a small number of species that have had research completed a nd additional research is needed to understand the complexities of CO 2 balances by the type of materi al being used for biogenic – bioenergy. The research also n eeds to factor in the effects of mixing different sources of

biomass and the amount of CO 2 produced either individua lly by species or mixedSummary of Interagency Working Comments Submitted during EO 128 66 Review Subject to Further Policy Review

materials. This burden should not be passed on to the users but should be applied nationally through EPA as a regulatory agency.

5) We disagree with the characterizatio n that . . . . activities such as prescribed fires have had “significant” contribution to the buildup of CO 2 in the atmosphere. [However, human activities, such as prescribed fires and land management practices, can also

influence the release of CO 2 from natural systems (i .e., anthropogenic biogenic CO 2 emissions) and these activities have ce rtainly contributed to the buildup of CO 2 in the atmosphere.]

We recommend that further research be c onducted to understand the amount of fires that burned historically either through natural or by anthropoge nic methods to promote the state of flora, fauna, etc that comprise many of the goods, servi ces, and experiential benefits that we as peoples use and partake of in life. The assumption that prescribed fires are contributing to CO 2 build up in the atmosphere relative to the amount of CO 2 from these historical processes may indeed a nd is most likely incorr ect. From the science and research conducted to date the number, ex tent, and magnitude of fires has drastically

been reduced from the historical amount necessa ry to conserve flora, fauna, etc that rely on fire as a life cycle event.

6) We support the information and rationale which states, “Subjecting biogenic CO 2 emissions to permitting may be counterproduct ive because it could discourage utilization

of the biomass feedstock as fuel.” This t ype of action could indeed have unforeseen consequences relative to fire management, fire control, and use of carbon in supporting energy needs.

7) Disagree with the assessment that states “t he rule will not have a significant economic impact on a substantial number of small entitie s. Small entities include small businesses, small organizations, and small governmental jurisd ictions.” This rule has the potential to dramatically adversely affect local and ru ral communities and economies that have had years of uses of biomass as an important source material to small businesses through the timber industry and local energy needs.

Comments on Deferral:

8) Change LUCF to LULUCF throughout this document and the guidance document to represent Land Use, Land-use Change and Forestry.

9) A definitional note here --- we think that the terminology in the deferral and guidance documents need to refer to “biogenic-origin” CO2 emissions and fuels, instead of simply just “biogenic” CO2 emissions. Biogenic emissions are from living things; whereas biogenic-origin emissions come from living th ings or the combustion of previously living things. This is consistent with IPCC and previous EPA documents (e.g., www.epa.gov/ttn/chief/ap42/ch14/ ).Summary of Interagency Working Comments Submitted during EO 128 66 Review Subject to Further Policy Review

10) Page 9: “Third, concurrent with this rule making, we are providing an interim guidance document (discussed further in section III.D.3) to help permitting authorities establish a basis for concluding that BACT for biogenic CO 2 emissions at stationary sources can simply be combustion of biomass fuels.”

11) Page 9: “Fourth, EPA will be conducting a deta iled examination of the science associated with biogenic CO 2 emissions from stationary so urces, including engaging with partners within the federal government, such as th e US Department of Agriculture and the Department of Energy, as well as scientists outside of it with relevant expertise to

consider scientific and technica l issues that the Agency must resolve in order to account for biogenic CO 2 emissions in ways that are scientif ically sound and also manageable in practice (discussed further in section II.C and II.D).”

12) Page 11: “In this action we are addressing only the CO 2 emissions from biogenic- origin sources, not emissions of other GHGs or non-GHG pollutants. The term “biogenic- origin

CO 2 emissions” is defined here as emissions of CO 2 from a stationary source directly resulting from the combustion or decompos ition of biologically-bas ed materials other than fossil fuels. Examples of “biogenic -origin CO 2 emissions” include, but are not

limited to:

13) CO 2 from the combustion of biogas collected from biological decomposition of waste in landfills, wastewater treatment or manure management processes;

 CO 2 from combustion of the biological fraction of municipal solid waste or biosolids; and

 CO 2 from fermentation during ethanol production;

 CO 2 from combustion of the biologica l fraction of tire-derived fuel.

14) Page 16: While we are presenting this inform ation for context, as explained in that section and in latter parts of this preamble, the Inventory is an a nnual report that tracks

US GHG emissions and sinks at the national scale.

15) Page 18: “Stored carbon can be released na turally back into the atmosphere as CO 2 through decomposition or plant respiration. When biological material such as plant

biomass is harvested or cleared from the land and then burned for energy, used as an input to an industrial pr ocess, or biodegraded as part of waste treatment process , the

material acts as a source of carbon, releasing its stored car bon back into the atmosphere

as CO 2 .”

16) Page 21: “The Inventory is a co mprehensive report of emissions and sinks at the national scale. All biogenic CO 2 emissions and sinks , as defined in this defe rral, are also included in the Inventory...”

17) Page 23: “As noted earlier, when trees are harvested and combusted to generate bioenergy the CO 2 combustion emissions do not occur in the forest but rather in a power plant or industrial facility . Following the convention established by the IPCC in theSummary of Interagency Working Comments Submitted during EO 128 66 Review Subject to Further Policy Review

Guidelines, EPA counts those emissions as part of the forestland sector for the official US Inventory submission ...”

18) Page 26-27: “Another wa y in which biogenic CO 2 differs from fossil CO 2 , as well as from other regulated pollutants, is the sometimes ambiguous link between the net emissions caused by human activities and those that occur as part of the natural background emission fluxes. For example, natural fires, decomposition, and plant respiration all result in substantial short-lived biogenic emissions of CO 2 . These transfers

of CO 2 between land and atmosphere are critical to the maintenance of life on Earth. However, human activities, such as as prescribed fires and land and forest management practices, can also influence the flux (i.e., release and uptake ) of CO 2 from natural

systems (i.e., anthropogenic biogenic CO 2 emissions) and these acti vities have certainly contributed to the buildup of CO 2 in the atmosphere. . There are challenges in categorizing the biogenic CO 2 emissions that would have occurred naturally and those attributable to human activity. While the Inventory accounts for all anthropogenic biogenic CO 2 emissions at the national level, this deferral and the Agency’s intent to collaborate with federal partners and the scientific community to conduct a detailed

examination of the science associated with biogenic CO 2 emissions and technical issues in accounting for those emissions at stationary sources is an effort to better characterize these distinctions and the associated impacts...”

19) Page 29: “The EPA has reiterated thes e CAA requirements in its long-standing regulations that implement PSD , although it interpreted thes e requirements narrowly so that they apply only with resp ect to air pollutants that are subject to regulation under the

CAA. Specifically, under EPA’s regulations,...”

20) Footnote 19: “Though this proposed rule concerns emissions from stationary sources, we

note that various motor vehicle fuels are de rived from plant material. For example, ethanol can be produced from pl ant starch or cellulose, and diesel fuel can be produced from various plant oils. The Energy Inde pendence and Security Act of 2007 (EISA) required EPA, in the context of implementi ng the renewable fuel program under section 211(o) of the CAA, to evaluate the lifecycl e greenhouse gas emissions of these and other

motor vehicle fuels. EISA defines lifec ycle greenhouse gas emissions as “...the aggregate quantity of greenhouse gas emi ssions (including direct emissions and significant indirect emissions such as signifi cant emissions from land use changes), as determined by the Administrator, related to the fu ll fuel lifecycle, including all stages of fuel and feedstock production and distributi on, from feedstock gene ration or extraction through the distribution and de livery and use of the finished fuel to the ultimate

consumer...”. EPA’s analysis of the various fuel s demonstrated that multiple factors, including the type of feedstock used, resulted in a wide variation in their associated lifecycle GHG emissions. For example, from a lifecycle perspective some of the analyzed motor vehicle fuels result in very large reductions in GHG emissions compared to the fossil fuel they replace, while others do not. The lifecycle analyses of the motor vehicle fuels took into account a wide range of factors, including th e carbon sequestration

associated with the biomass. See 75 FR 14670, 14764-799 (March 26, 2010).Summary of Interagency Working Comments Submitted during EO 128 66 Review Subject to Further Policy Review

21) Page 58: “As part of that examination we intend to engage with partners within the federal government, such as the US Departme nt of Agriculture and the Department of Energy, as well as scientists outside of it with relevant expertise to ensure a robust review

of the scientific and tech nical issues associated w ith this type accounting...”

22) Page 59: “While the interim guidance describe d in section III.D will help alleviate some

of this burden in Step 1 of the Tailoring Rule (which runs from January 2, 2011 to July 1, 2011), we expect that more and more diverse users of biomass combustion or other biogenic CO 2 sources are likely to be affected under Step 2...”

23) Page 62: “...In light of the way these regulat ions are currently wr itten and interpreted, EPA is unable to exclude biogenic- origin CO 2 emissions from PSD review. Stationary sources of air pollutants, in cluding sources of biogenic- origin CO 2 emissions, are currently subject to PSD requirements because they emit more than 100 or 250 tpy of a regulated NSR pollutant other than GHG and have triggered PSD as a result of these emissions. We call these sources “anyway ” PSD sources, and bioenergy and other sources of biogenic- origin CO 2 emissions may be among them based on emissions of pollutants other than GHG. Under the Tailoring Rule, as of January 2, 2011...”

24) Page 64: “...Tailoring Rule), and as a re sult, emissions of GHG, including biogenicorigin CO 2 emissions, are considered in determini ng whether a source is subject to Title V as of July 1, 2011...”

25) Page 65: “...Therefore, absent some further regulatory action, EPA is unable to exclude biogenic- origin CO 2 emissions from the appl icability of Title V...”

26) Page 70: “...For example, this includes residue material (such as sawdust from milling operations) that would have decomposed under natural circumstances in a relatively short period of time (e.g., 20 years )...”

27) Page 79: “...Because other non-GHG pollutants and non-CO 2 GHGs do not participate in natural biogeochemical carbon cycles as CO 2 does, this frame of reference – in which sequestration outside the facility is considered as part of the...”

28) Page 83: “...Thus, states that cannot interpre t their PSD SIP or Title V requirements to incorporate the three-year de ferral are strongly encouraged to submit SIP revisions or Title V program revisions to adopt the three- year deferral. Doing so would allow these states to avoid applying PSD requirements to biogenic-origin CO2 emissions during the period needed for further study.

29) Page 83: “... However, EPA recognizes that some st ates may not have any, or may have only a few, sources that combust biomass, and may have adequate information and

resources as to the nature of b iogenic emissions from those sources. For those states, the deferral may not be appropriate. Accordingly, EPA requests each state to advise EPA by letter, during the comment period for this propos al, as to the number and type of biomass

sources in their state.Summary of Interagency Working Comments Submitted during EO 128 66 Review Subject to Further Policy Review

30) Page 86: “This action does not impose any ne w information collection burden. Instead,

this action will reduce costs incurre d by any facility with biogenic- origin CO 2 emissions, as well as permitting authorities, relative to th e costs that would be incurred if EPA did

not revise the rule.

GUIDANCE FOR DETERMINING BEST AVAILABLE CONTROL TECHNOLOGY

FOR REDUCING CARBON DIOXIDE EMISSIONS FROM BIOENERGY

PRODUCTION

31) Page 2: “III. EPA’s Previous Actions Re lating to Application of PSD Program to Biogenic- origin CO 2 Emissions.”

32) Page 3: “...This guidance provides an illust ration of reasoning that a Prevention of Significant Deterioration (PSD) permitting au thority may use to support the conclusion

that the best available control t echnology (BACT) for carbon dioxide (CO 2 ) emissions at a bioenergy facility is the combustion of biogenic- origin fuels alone...”

33) Footnote 1: A ‘bioenergy facility’ is define d, for the purposes of this guidance, as a facility that generates ener gy via the combustion of biologi cally-derived material other than fossil fuels( for example but not limited to wood, biogas, biofuels, agricultural products, forest slash, etc ). This could be undertaken either alone or in addition to

traditional fossil fuels.

34) Page 4: “... Any stationary source, including a bioenergy facility, that qualifies as a major stationary source is required to obtain a PSD permit and must address the BACT requirement for GHGs if it emits or increases its emission of this regulated pollutant in amounts greater than 75,000 tons on a CO 2 e basis. This guidance on determining BACT

for CO 2 emissions from a dedicated bioenergy facility or facilities that utilize biogenicorigin fuels is intended to supplement the 2010 GHG Permitting Guidance, and not to supersede it...”

35) Page 4: “...Concurrent with th e release of this guidance, EPA is issuing a proposed rule to defer application of PSD permitting requirements to CO 2 emissions from biologicallybased material (biogenic- origin CO 2 emissions) for a three-year period...”

36) Page 5: “...To the extent no such deferral is available under the PSD permitting regulations applicable at the time a permitting authority issues a PSD permit for a facility with biogenic-origin CO2 emissions, the reasoning described below may be used on an interim basis to support a conclusion in such a permit that BACT for CO 2 is combustion

of biomass fuels alone...”

37) Page 5: “..However, EPA believes the analysis described below will be sufficient in most cases to support the conclusion that utilization of biomass fuel alone is BACT forSummary of Interagency Working Comments Submitted during EO 128 66 Review Subject to Further Policy Review

bioenergy facilities and can be considered as BACT for other facilities with biogenicorigin fuels CO2 emissions...”

38) Page 5: “...It is also important to note that this guidance is meant to be interim guidance only and that once a pending detailed examinations of the science and technical issues associated with accounting for biogenic-origin CO 2 emissions from stationary

combustion sources

, as discussed in the proposed deferral

.

39) Page 6: “...The term ‘CO 2 emissions from bioenergy’ is us ed in this guid ance to describe biogenic- origin fuel CO 2 emissions from a stationary source that directly result from the combustion of biologically-based materials ot her than fossil fuels when these materials are used to generate energy...”

40) Page 7: “...EPA’s Inventory of U.S. Greenhouse Gas Emissions and Sinks (the Inventory) tracks annual GHG emissions and sinks including emissions of CO 2 , methane (CH 4 ), nitrous oxide (N 2 O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), and sulfur hexafluoride (SF 6 ). That report estimates all anthropo genic sources and sinks of

GHG emissions at the national scal e, classified into six broa d sectors: Energy, Industrial Processes, Solvents and Othe r Product Uses, Agriculture, Land Use , Land-Use Change and Forestry ( LULUCF ), and Waste. The Energy Sector includes all GHGs emitted during the production, transformation, handling and consumption of energy commodities, including fuel combustion. The LULUCF Sector includes emissions and sequestration...”

41) Page 8: “...Biogenic- origin CO 2 emissions are distinct from other regulated pollutants at bioenergy facilities because, unlik e other pollutants and other GHGs, CO 2 emissions can participate directly in the global carbon cycl e through photosynthesis, wh ich is critical for

the maintenance of life on Earth....”

42) Page 8: “...On the basis of the Invent ory results described above and other considerations, stakeholders ha ve requested that EPA exclude, either partially or wholly, biogenic- origin CO 2 emissions for the purposes of th e BACT analysis and the PSD program based on the view that the biological material...”

43) Page 9: “...In response, when finalizing the Tailoring Rule, EPA acknowledged the role that biogenic- origin fuels and feedstocks could play in reducing anthropogenic GHG emissions, and did not dispute the commenters’ observations that many state, federal, and international rules and policies treat biogenic sources and fossil sources of CO 2 emissions differently. [1] Nevertheless, we determined that we lacked a sufficient record at that time to apply the legal rationales ut ilized in the Tailoring Rule to exclude emissions of CO 2 from biogenic sources in determining permitting applicability provisions. At that time, we had not requested and did not obt ain public comments addressing the scientific and technical challenges of permitting projects that sp ecifically involve biogenic- origin CO 2 emissions from energy production...”

[1] See 75 FR 31514.Summary of Interagency Working Comments Submitted during EO 128 66 Review Subject to Further Policy Review

44) Page 10: “..In order to ex plore the issue further follo wing the promulgation of the Tailoring Rule, in July 2010 EPA solicited vi ews from the public through a Call for Information (CFI) on approaches to accounti ng for biogenic emissions, including whether some or all of a source's biogenic- origin CO 2 emissions could be discounted based on a determination that they are canceled out by the CO 2 absorption associated with growing the fuel. Also, we solicited informati on on the means to estimate and measure CO 2 emissions from a variety of biogenic- origin fuels...”

45) Page 10: “...To assist permitting authoritie s carrying out BACT analyses for GHGs until EPA took further action, the gui dance indicated that permitting authorities may consider the environmental, energy and economic benefits that may accrue from the use of certain types of biogenic fuels (e.g., biogas from landfills) for energy generation, considering these ancillary benefits is consistent with existing air qua lity standards. Noting that a variety of federal and state policies have recognized that some biogenic fuels and fuels of biogenic origin can be part of a national strategy to reduce dependence on fossil fuels and to reduce emissions of GHGs, EPA determin ed that it is appropriate for permitting authorities to account for both existing fede ral and state policies and their underlying objectives in evaluating the environmental, energy and economic benefits of biogenicorigin fuels...”

46) Page 10: “...EPA observed that, based on these considerations, permitting authorities might determine in the GHG component of th e BACT analysis for new or modified bioenergy facilities, as defined in Secti on I, that such uti lization of biogenic- origin fuels is inherently BACT for GHGs. ...”

47) Page 11: “...To assist permitting authorities further in considering these factors, EPA announced its intent to issue guidance that will provide a suggested framework for undertaking an analysis of the environmental, energy and economic impacts of using biogenic- origin fuels in Step 4 of the top-down BACT process...”

48) Footnote 27: “As noted above, a control opti on is “available” if it has a potential for practical application to the emissions unit a nd the regulated polluta nt under evaluation. Thus, even technologies that are in the ini tial stages of full development and deployment for an industry, such as utilizing fuel mixtures with a biomass component , can be

considered “available” as that term is used for the specific purposes of a BACT analysis under the PSD program. End of FN.”

49) Page 16: “...include compara tive evaluation of biogenic- origin fuels and other types of fuels, including fossil fuels.

However, where a proposed bioenergy facility can demonstrate that utilizing a particular type of biogenic- origin fuel is fundamental to the primar y purpose of the project, then at the first step of the top-down process, permitting authorities can rely on that to determine

that use of another fuel would redefine the proposed source...”Summary of Interagency Working Comments Submitted during EO 128 66 Review Subject to Further Policy Review

50) Page 16: “...In cases where a permit applicant proposes to co-fire or combine biomass fuels with another primary fuel type as BACT , the list of options should include the option of utilizing both types of primary fuels in different combinations . If the applicant proposes a specific proportional allocation or fuel mix ( e.g., < 5 percent biomass, > 95 percent fossil fuel)...”

51) Page 21: “Within the context of the PSD progr am, a potential justification that biogenicorigin CO 2 emissions can be accounted for differently than non-biogenic- origin CO 2 emissions at the facility relies on th e argument that sequestration occurs...”

52) Page 22: “...Because other pollutants and non-CO 2 GHGs do not participate in the natural biogeochemical carbon cycle to the same extent that CO 2 does, this frame of reference – in which the potential for sequest ration outside the facility of pollutant subject to the BACT analysis is considered as part of the environmental impacts at Step 4

– is not relevant for those other pollutants...”

53) Page 22: “...This type of facility-specific approach would also likely be the most scientifically sound approach for assessing th e direct carbon cycle impact of specific biogenic- origin fuels used at the facility, because there is inherent variability in biological processes, as well as the variability in space and time common to estimates of sequestration. ...”

54) Page 23: “...In the context of bioenergy and biogenic- origin emissions, where such a wide variety of potential feedstocks exis ts, the BAU case might be considered the emissions that “would have happened anyway.” Using this approach, a permitting authority would have to assess the extent to which a policy action or an activity increases

or reduces CO 2 emissions above or below what woul d have occurred in comparison to the BAU case. From the perspective of bioenergy and other biogenic- origin emissions,

emissions that would have occu rred regardless of whether or not the facility captured the energy from the biofuel use or carried out the process usi ng biological material as a feedstock might demonstrate that the cost of additional pollutant controls is not justified....”

55) Page 24: “...Given that this material would have decomposed under natural circumstances in a short period of time (e.g ., 20 years ) in the absence of utilization as bioenergy, this conclusi on appears credible...”

56) Page 25: “Upon further review, EPA has conclude d that it requires fu rther scientific and technical input from other federal agencies and outside scientific experts panel before it can make more qualitative ch aracterizations beyond the one described above for residue

material...”

57) Page 25: “...As with other electric generating facilities, these direct costs will generally make the price of electricity from bioene rgy used in conjunction with add-on control technologies for CO 2 uncompetitive compared to electric ity from plants with other GHG controls, such as bioenergy alone or use of biogenic-origin fuels

. ...Summary of Interagency Working Comments Submitted during EO 128 66 Review Subject to Further Policy Review

58) Page 27: “...Such policies can improve the economy, especially in rural communities, by generating jobs, income, and taxe s through demand for local biogenic- origin resources and construction of bioenergy conversion faci lities. Specifically, an improved market for biogenic- origin fuels and forest land could aff ect economic stabilization through increased incomes (from new jobs), highe r local tax base and possibly through the diversification of local energy sources, and increased competition could lower energy prices. ...”

59) Page 28: “...Other potential indirect economic considerations from biomass utilization as BACT could include, but are not limited to, increased demand for traditional or new crops and reduced disposal costs for biogenic- origin materials that would otherwise be landfilled or destroyed...”

60) Page 28: “...For faciliti es utilizing biogenic- origin fuels (e.g., biogas and sawdust), it is appropriate to broaden the scope of the energy impacts analysis to c onsider policies that seek to promote diversity in fuels used in a local area, within a state, or nationally...”

61) Page 29: “...However, consideration of rene wable energy policies could become part of the BACT analysis, especially if state policies mandate the re placement of fossil fuel with biogenic- origin fuel....”

62) Page 29: “...Conversely, if the proposed biogenic- origin feedstock is scarce in the localized area of the proposed project, then the scarcity of available fuel for the project might be an energy impact suggesting that th e proposed feedstock should not be selected

as BACT....”

63) Page 29: “...The considerations described above can support a conclusion that the

exclusive utilization of biomass fuel is BA CT for greenhouse gases at a bioenergy facility and can be considered as a potential BACT st rategy for facilities that utilize mixed fossil and biogenic fuel sources ...”

64) Page 30: “...Furthermore, in the case of residue material that would otherwise decompose in a 20 year time frame..”

65) Page 31:. “... as described above. Utilization of biomass fuels will can reduce dependence on fossil fuels and promote economic growth in areas that supply biomass

fuels. Utilization of even a small proportion of biomass fuel use may complement opportunities to reduce GHG emissions by improving energy efficiency at a facility that still combusts a significant proportion of fossil fuels. When assessing the proportional allocation for biomass and other fuel types at a co-fired energy facility, a permitting authority may consider the relative energy e fficiency of using a greater proportion of biomass fuels and the effect this may have on GHG emissions from an individual facility. Where a residue material or other biogeni c-source fuel is utilized, any loss of energy efficiency attributable to the use of th is type of biomass feedstock may be offsetSummary of Interagency Working Comments Submitted during EO 128 66 Review Subject to Further Policy Review

by the absence of a significan t net carbon cycle impact a bove the business as usual

case...”

66) Page 32: “...When setting GHG emissions limitations for sources of biogenic- origin CO 2 emissions, one should conduct the same eval uation as that described in the 2010 GHG Permitting Guidance...