### Fw: Deliberative points for intera gency discussion at 5pm today Michael Ling

to: Pam Long 05/13/2010 11:00 AM Show Details

OMB docket item

Michael Ling Associate Director Air Quality Policy Division U.S. EPA - OAQPS (919) 541-4729

-----Forwarded by Michael Ling/RTP/USEPA/US on 05/13/2010 11:00AM -----

To: Michael Ling/RTP/USEPA/US@EPA From: "King, Heidi R." <Heidi_R._King@omb.eop.gov> Date: 04/27/2010 04:40PM Subject: Deliberative points for interagency discussion at 5pm today

1. Including biogen ic carbon emissions : It is universally recognize d that the contributions of biogenic carbon sources to the buildup of g reenhouse gases in the atmosphere cannot be established simply though the quantification of direct emissions from biogenic sources. All biogenic carbon sources must be evaluated in terms of their net contributions (emissionsremovals). This approach is used in the IPCC GHG Inventory Methods, in guidance provided under the 1605(b) Voluntary Greenhouse Gas Registry, and is relied on in the preparation of the Official Inventory of GHG Emissions and Sinks (p repared by EPA for subm ission to the UNFCCC each year). This premise is also the basis of EPA’ s use of lifecycle analysis in the RFSII. Only accounting for the direct emissions and not also in cluding carbon sequestration leads to absurd results. All uses of food, feed , animal products, and organic wa stes lead to the emissions of biogenic carbon. We do not belie ve that EPA intends th at all of these sources of direct biogenic carbon be tracked. For example, 23.5 million tons of biogenic materi als were rendered in 2002, virtually all of this was eventually emitted to the atmosphere. We do not believe that it is necessary or wise to pursue emissions permits fr om renders, food processors, lumber mills, pulp and paper operations, waste water treatment facilitie s, or landfills for the emissions of biogenic carbon in the form of CO2.

2. The potential for the inclusion of biogenic carbon to lead to unrealistic administrative burdens : The RIA that accompanies the Tailoring rule does not appear to consider biogenic carbon in its analysis. It is also unclear fr om the rule and the RIA whether non-combustion sources of emissions are to be included. Finally, it is unclear whether the rule would apply to emissions that do not come from a stack or vent. A large quantity of biogenic carbon emissions are associated with respiration and decomposition, or result from field burning or prescribed and wild forest fires.

3. Defering the decision on the inclusion of bi ogenic carbon until further analysis is available : In reviewing the rule and accompanying RIA, it is clear that EPA has the discretion to phase-in its 

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5/13/2010 file://C:\Documents and Settin g s\ p lon g \Local Settin g s\Tem p \notesFCBCEE\~web1145.htmimplementation of the rule. EPA could decide not to include biogenic carbon under the rule until further analysis is conducted. EPA has the discret ion to cover biogenic sources of carbon as part of Step 3 of the rule which requires EPA to prom ulgate by July 1, 2012, on the consideration of phasing-in additional sources. As part of this approach, EPA could commit to complete a study of the implications of including biogenic carbon by April 30, 2015. 

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5/13/2010 file://C:\Documents and Settin g s\ p lon g \Local Settin g s\Tem p \notesFCBCEE\~web1145.htm