Fw: Deliberative points for interagency discussion at 5pm today

Michael Ling 

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Pam Long 

05/13/2010 11:00 AM 

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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 biogenic carbon emissions: It is universally recognized that the contributions of 

biogenic carbon sources to the buildup of greenhouse 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 (prepared by EPA for submission 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 including carbon sequestration leads to absurd 

results. All uses of food, feed, animal products, and organic wastes lead to the emissions of 

biogenic carbon. We do not believe that EPA intends that all of these sources of direct biogenic 

carbon be tracked. For example, 23.5 million tons of biogenic materials 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 from renders, food processors, lumber mills, pulp 

and paper operations, waste water treatment facilities, 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 from 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 biogenic 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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implementation of the rule. EPA could decide not to include biogenic carbon under the rule until 

further analysis is conducted. EPA has the discretion to cover biogenic sources of carbon as part 

of Step 3 of the rule which requires EPA to promulgate 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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