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This rule is based on the EPA’s basic premise that burning biomass for energy is considered to be carbon-neutral when considered in the context of natural carbon cycling: Although the burning of biomass also produces carbon dioxide, the primary greenhouse gas, it is considered to be part of the natural carbon cycle of the earth. The plants take up carbon dioxide from the air while they are growing and then return it to the air when they are burned, thereby causing no net increase. Biomass contains much less sulfur and nitrogen than coal; therefore, when biomass is co-fired with coal, sulfur dioxide and nitrogen oxides emissions are lower than when coal is burned alone. When the role of renewable biomass in the carbon cycle is considered, the carbon dioxide emissions that result from co-firing biomass with coal are lower than those from burning coal alone (EPA, 2010). Regarding consideration of life-cycle emissions, the EPA has stated that preparation of a complete life cycle analysis is beyond the scope of this rule: With respect to emissions and sequestration from agricultural sources and other land uses, the rule does not require reporting of emissions or sequestra- tion associated with deforestation, carbon storage in living biomass or harvested wood products. These catego- ries were excluded because currently available, practical reporting methods to calculate facility-level emissions for these sources can be difficult to implement and can yield uncertain results. Currently, there are no direct GHG emission measurement methods available except for research methods that are very expensive and require sophisticated equipment (EPA, 2009). Regarding biomass-derived transportation fuels, the Energy Independence and Security Act of 2007 (EISA) (P.L. 110–140) required EPA to establish a rule for mandatory lifecycle GHG reduction thresholds for various renewable liquid transporta- tion fuel production pathways, including those using wood as a feedstock. Each qualifying renewable fuel must demonstrate that net GHG emissions are less than the lifecycle GHG emissions of the 2005 baseline average for the fossil fuel that it replaces. For non-agricultural feedstocks, renewable fuel producers can comply with the regulation by: (1) collecting and maintaining appropriate records from their feedstock suppliers in order to demonstrate that feedstocks are produced in a manner that is consistent with the renewable biomass requirements outlined in the ruling, or (2) fund an independent third party to conduct annual renew- able biomass quality-assurance audits based on an a framework approved by EPA. 1.3.3 PendingFederalClimateandEnergy Legislation Pending federal climate and energy legislation continues to be in flux, with an uncertain future and significantly evolving content. Overall, these bills focus primarily on the production of renew- able electricity and transportation fuels rather than production of thermal energy. In all of the various versions of these bills, energy produced from biomass is considered to be renewable and carbon neutral and generally excluded from proposed caps on carbon emissions and related proposals for carbon emission allowances. There is continuing debate about the definition of biomass from qualifying sources and various proposals to provide safeguards for natural resources on public and/or private lands. This debate also includes consideration of sustainability require- ments or guidelines for biomass to qualify as a renewable fuel. There is concern that aggressive targets for increasing the use of biomass for production of renewable electricity and transporta- tion fuels from the current Renewable Fuels Standard, a proposed Renewable Electricity Standard and a limit on carbon emissions would outstrip the capacity of our nation’s forests to provide an economically and ecologically sustainable supply. To ensure sustainable harvesting levels and accurate accounting of carbon emissions and re-sequestration, there is discussion and debate about including emissions from renewable biomass energy under proposed carbon caps based on full lifecycle accounting. At this point, however, it is unclear what direction will emerge in this developing legislation. 1.4 MASSACHUSETTS FOREST BIOMASS ENERGY POLICIES Massachusetts has implemented policies to increase the use of biomass to meet energy needs in the electricity sector, the transportation sector, and the building heating sector, although as is the case at the federal level, state policies have been focused primarily on using biomass to replace fossil fuels in the electricity and transportation sectors. Combined with the state’s regulatory structure for implementing the Regional Greenhouse Gas Initia- tive (RGGI) (which sets an emissions cap on fossil fuel electrical generation systems of 25 megawatts or greater), this has created significant incentives driving the state towards greater reliance on biomass electric generation capacity. A recent exception to this trend is the Massachusetts Green Communities Act of 2008, which established new Renewable and Alternative Energy Portfolio Standards (RPS and APS) that allow eligible CHP units to receive credits for useful thermal energy. This program promotes the installation and effective operation of new CHP units for residential, commercial, industrial, and institutional applications. Overall, the bill significantly reforms the state’s energy policy, and makes large new commitments to electric and natural gas energy efficiency programs, renewables, and clean fossil fuels like combined heat and power (Environment Northeast, 2008). Massachusetts has two regulatory programs that directly impact the incentives for developing biomass-fueled electricity in the state. The first is the Massachusetts Renewable Portfolio Stan- dard (RPS), which is administered by the Department of Energy Resources (DOER), and the second is the implementation of the state’s membership in the Regional Greenhouse Gas Initiative (RGGI), which is administered by the Department of Environ- mental Protection (DEP). BIOMASS SUSTAINABILITY AND CARBON POLICY STUDY MANOMET CENTER FOR CONSERVATION SCIENCES 15 NATURAL CAPITAL INITIATIVEPDF Image | NATURAL CAPITAL INITIATIVE AT MANOMET
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