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Steve Prisley 2012 National FIA User Group Meeting FIA DATA AND THE EPA ACCOUNTING FRAMEWORK FOR BIOGENIC CO 2 EMISSIONS

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OVERVIEW Background: EPA regulating CO 2 emissions; different treatment for biogenic CO 2 ? Proposed accounting framework and role of FIA data Issues and challenges Photo: 24dash.com 2

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BIOENERGY AND CARBON NEUTRALITY Biomass: forests, agricultural products, wastes & residues IPCC approach for national GHG inventories: treats emissions from biomass energy as carbon-neutral Premises for carbon neutrality of biomass emissions: They contain carbon that was taken from the atmosphere They will be recaptured by subsequent regrowth of plants They would have occurred anyway They are part of a short-term cycle relative to fossil fuel emissions European stance: biomass energy is carbon neutral (for now) 3

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RECENT EPA ACTIONS ON BIOGENIC CO 2 EMISSIONS EPA, under Clean Air Act, establishes thresholds for stationary sources emitting CO 2 under PSD permitting August 2010 - NAFO files petition for reconsideration of Tailoring Rule regarding treatment of biomass emissions January 2011 Agency grants NAFO petition for reconsideration of Tailoring Rule, and announces plans to defer applicability of PSD to bioenergy and other biogenic sources (PSD Deferral Rule) 4

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RECENT EPA ACTIONS ON BIOGENIC CO2 EMISSIONS March 2011 Deferral Rule and Guidance are published; includes plans for a detailed examination of the science related to accounting for biogenic CO 2 emissions May-Sept. 2011 Technical team development of draft framework Oct-Dec.2011 Review by EPA Science Advisory Board (SAB) March/April 2012- SAB Report expected Next: revisions to framework? 5

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AN ACCOUNTING FRAMEWORK TO ADJUST BIOGENIC CO 2 EMISSIONS FROM STATIONARY SOURCES A unique framework is needed that: Accounts for a stationary sources onsite CO 2 emissions, taking the biological cycling of carbon into consideration, in a scientifically and technically rigorous manner Provides the critical link between direct emissions from source and dynamics occurring in terrestrial biosphere Creates an adjustment factor that can be applied to direct emissions 6

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TECHNICAL TEAM Oversight: Jen Jenkins, Sara Ohrel; EPA Facilitation/Coordination: Mark Flugge, Diana Pape; ICF International Technical Team: Thomas Buchholz, Spatial Informatics Group Charles Canham, Cary Institute of Ecosystem Studies Katie Hanks, RTI International Gregg Marland, Appalachian State University Bruce McCarl, Texas A&M University Stephen Ogle, Colorado State University Steve Prisley, Virginia Tech Neil Sampson, The Sampson Group 7

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FRAMEWORK GOALS Accurately reflects the carbon outcome. Is scientifically rigorous/defensible. Is simple and easy to understand. Is simple and easy to implement. Is easily updated with new data. Uses existing data sources. 8

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DEFINING THE SCOPE 9

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POTENTIAL APPROACHES Use U.S. GHG Inventory as a proxy for national scale assessment of carbon stocks on land: Biogenic CO 2 emissions at stationary sources do not contribute to atmospheric load as long as the LULUCF sector in the U.S. is a net sink Categorical exclusion: Based on assumption that because biogenic feedstocks grow, biogenic CO 2 never contributes to atmospheric load No assessment of carbon stocks or link to the land Categorical inclusion: Biogenic CO 2 = fossil CO 2 emissions at the stationary source No assessment of carbon stocks or link to the land Lifecycle emissions analysis: Comprehensive way to assess net GHG emissions from use of biogenic fuel versus fossil fuels 10

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SELECTED APPROACH: FEEDSTOCK-BASED Feedstocks differ in their likely impact on atmospheric CO 2 : Feedstocks with similar properties or uses can be grouped together Management/harvest characteristics might distinguish feedstocks Alternative fates (i.e., anyway emissions): waste/residues, salvage 11

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SELECTED APPROACH: FEEDSTOCK-BASED Three broad categories of biologically-based materials that might be used in a stationary source: 1. Forest-Derived Woody Biomass 2. Agricultural Biomass 3. Waste Materials Photo: Emily Jane Davis, from Biomass magazine Photo: CleanTechnica.com Photo: Biomass magazine 12

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PREMISE OF THE FRAMEWORK Emissions from a stationary source can be considered carbon-neutral to the extent that: They are subsequently captured by vegetation regrowth, or They would likely have occurred anywa y Framework will calculate a Biomass Accounting Factor (BAF) to represent the extent to which these criteria are met. 13

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Stationary Source Sequestration Atmosphere FEEDSTOCK NEEDED SEQUESTERED FRACTION CARBON CONTAINED IN PRODUCTS AND BYPRODUCTS DIRECTEMISSIONS EMISSIONSFROMLAND- USE & MANAGEMENT CHANGES EMISSIONS FROM LEAKAGE FEEDSTOCK IN STATIONARY SOURCE FEEDSTOCK LOSSES DURING TRANSPORT & STORAGE FEEDSTOCK GROWTH ACCOUNTING FRAMEWORK SCHEMATIC 14

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Stationary Source Sequestration Atmosphere PGE L (1 PRODC) PGE SEQP PGE PRODC PGE (1 SEQP PRODC) PGE L PRODC SITE - TNC (1 PRODC) LEAK (1 PRODC) PGE (1+L) PGE PGE (1+L) LAR PRODC + PGE (1+L) LAR (1 PRODC) ACCOUNTING FRAMEWORK SCHEMATIC 15

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NBE = PGE (1 + L) (1 LAR) (1 PRODC) PGE SEQP + SITE_TNC (1 PRODC) + LEAK (1 PRODC) BAF = NBE / PGE NBE: Net Biogenic EmissionsPRODC: Product Carbon (%) PGE: Potential Gross EmissionsSEQP: Sequestered Proportion LAR: Level of Atmospheric ReductionSITE_TNC: Total Net Change at Site L: Losses in transport/storage FRAMEWORK EQUATION Where does FIA fit in? 16

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Stationary Source Sequestration Atmosphere FEEDSTOCK NEEDED SEQUESTERED FRACTION CARBON CONTAINED IN PRODUCTS AND BYPRODUCTS DIRECTEMISSIONS EMISSIONSFROMLAND- USE & MANAGEMENT CHANGES EMISSIONS FROM LEAKAGE FEEDSTOCK IN STATIONARY SOURCE FEEDSTOCK LOSSES DURING TRANSPORT & STORAGE FEEDSTOCK GROWTH ACCOUNTING FRAMEWORK SCHEMATIC 17

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Stationary Source Sequestration Atmosphere FEEDSTOCK NEEDED SEQUESTERED FRACTION CARBON CONTAINED IN PRODUCTS AND BYPRODUCTS DIRECTEMISSIONS EMISSIONSFROMLAND- USE & MANAGEMENT CHANGES FEEDSTOCK IN STATIONARY SOURCE FEEDSTOCK LOSSES DURING TRANSPORT & STORAGE FEEDSTOCK GROWTH ACCOUNTING FRAMEWORK SCHEMATIC 18

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Stationary Source Sequestration Atmosphere FEEDSTOCK NEEDED SEQUESTERED FRACTION CARBON CONTAINED IN PRODUCTS AND BYPRODUCTS DIRECTEMISSIONS FEEDSTOCK IN STATIONARY SOURCE FEEDSTOCK LOSSES DURING TRANSPORT & STORAGE FEEDSTOCK GROWTH ACCOUNTING FRAMEWORK SCHEMATIC 19

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Stationary Source Sequestration Atmosphere FEEDSTOCK NEEDED SEQUESTERED FRACTION CARBON CONTAINED IN PRODUCTS AND BYPRODUCTS DIRECTEMISSIONS FEEDSTOCK IN STATIONARY SOURCE FEEDSTOCK GROWTH ACCOUNTING FRAMEWORK SCHEMATIC 20

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Stationary Source Atmosphere FEEDSTOCK NEEDED CARBON CONTAINED IN PRODUCTS AND BYPRODUCTS DIRECTEMISSIONS FEEDSTOCK IN STATIONARY SOURCE FEEDSTOCK GROWTH ACCOUNTING FRAMEWORK SCHEMATIC 21

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Stationary Source Atmosphere FEEDSTOCK NEEDED DIRECTEMISSIONS FEEDSTOCK IN STATIONARY SOURCE FEEDSTOCK GROWTH ACCOUNTING FRAMEWORK SCHEMATIC Does regrowth balance adjusted emissions? 22

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ROLE OF FIA DATA Does regrowth balance emissions? Use FIA data to estimate net growth surplus over removals Compute LAR: LAR = (GROW + AVOIDEMIT) PGE * (1 + L) (Actually, LAR is capped at 1.0) GROW: tons CO2 sequestered in regrowth AVOIDEMIT: CO2 emissions that would have occurred anyway without energy production 23

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ROLE OF FIA DATA Recent growth exceeds removals (by more than PGE): LAR = 1 Recent growth is below removals: LAR = 0 Recent growth is positive but less than emissions: 0 < LAR < 1 24

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CASE STUDY EXAMPLE 30 MW electricity generation plant Consumes 1 bone dry ton wood per megawatt produced Consumes 250,000 tons wood per year Equal to 415,800 tCO 2 e (PGE) Transport/storage losses negligible (L = 0) 25

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CASE STUDY EXAMPLE Case 1: Source region = New England Annual sequestration in region: 60,484,044 tCO 2 e LAR = 1 (60,484,044 >> 415,800) BAF = 0 Case 2: Source region = New Hampshire Annual sequestration in region: 104,252 tCO 2 e LAR = (104,252 / 415,800) = 0.2507 BAF = 0.7493 26

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ISSUES Technical implementation issues: What is recent? Time scale for G/R? Where? Spatial scale? Compared to what? Baselines? Policy implementation issues: Time scale Leakage Opt-out? Certification? Import/export considerations Marginal versus average accounting 27

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TECHNICAL ISSUES: WHAT IS RECENT? Setting a time period for sequestration assessment is a policy decision Balance between time and space influences precision Approx. 5 years would (hopefully) represent a complete FIA measurement cycle in Eastern US Examine G/R within past survey period to compute regional GROW factors Update as new data become available 28

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TECHNICAL ISSUES: SPATIAL SCALE? Balance between time and space influences precision Working forest: consider ownership and availability National? Not responsive to local/regional imbalances Regional? Can have regional default factors- ease of use Arbitrary regions; woodsheds overlap Local? Need sufficient area for precision of estimates Default factors not feasible 29

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Baselines have been defined in at least three ways: 1. The net change from a current reference point Reference point baseline 2. The net change from a bounded business-as-usual future Anticipated future baseline 3. The net change from an alternative future Comparative baseline Includes consideration of alternative energy futures TECHNICAL ISSUES: BASELINES? 30

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POLICY ISSUES: TIME SCALE? Should CO 2 balances be projected into the future? Products leaving a stationary source are not counted: should future emissions from them be estimated? 31

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POLICY ISSUES: LEAKAGE? Leakage occurs when purchase of biomass for energy causes market reactions that may result in emissions elsewhere E.g., purchase of corn for ethanol production causes ripple effect among agricultural substitutes that results in unreported emissions Indirect land-use change is often a result How to quantify? How to verify? How to attribute responsibility? 32

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POLICY ISSUES: OPT-OUT? Should stationary sources be given the opportunity to opt- out of this framework? E.g., if they can document sustainability of supply and regrowth What are the reporting, verification burdens? Is third-party certification enough? Sources for such plants would need to be withdrawn from analyses for other plants how? 33

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Photo: James Lowe POLICY ISSUES: IMPORT/EXPORT Pellet export facility, Eastport, ME Exports impact G/R balance If no emissions, not in system Disincentive for domestic renewable energy? 34

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Photo: James Lowe POLICY ISSUES: MARGINAL/AVERAGE When new plants are permitted, G/R balance changes: whats fair? Existing plants grandfathered? BAF changes for everyone? Subsequent plants have BAF = 0? 35

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SUMMARY Accounting framework is a work in progress Inevitably, FIA data will be relied upon to provide estimates of growth/removals related to biomass energy Issues of FIA spatial scale, time scale, and working forest need resolution Technical and policy issues remain 36