Tailoring Rule Update

BPA / CBEA Joint Annual Meeting

February 29, 2012

The Platinum, Las Vegas

Gregg Morris

Future Resources Associates / Green power Institute

Tailoring Rule Timeline

9/30/09: EPA proposes Tailoring Rule for ghgs

6/03/10: Final Tailoring Rule adopted

7/10/10: Call for information on Bioenergy

1/12/11: Intent to defer TR for biogenic C

7/01/11: 3-year deferral granted for biogenic C

9/2011: Accounting framework for biogenic C

10/2011: First public meeting of the SAB

6/1012: SAB report on accounting framework

Accounting Framework

Introduces Biogenic Accounting Factor: BAF

Varies from 0 to 1, can be negative

Zero means carbon neutral

One means equivalent to fossil C

Negative means net reductions, possible offsets

Waste and residues have BAF = 0

SAB Draft Report

Critical of Accounting Framework (AF) simplifications

Endorses wastes and residues as carbon neutral

Critical of AF temporal and geographic treatment

Options: revise BAF, or scrap it entirely–Develop generic BAFs by feedstock type

–Require certification as sustainable for C neutrality

–Develop a system for granting offsets

Lingering Deficiencies

•While no need to regulate CH4 from biomass, must

include CH4 in carbon-cycle modeling

•Should consider dynamic modeling for temporal

issues

•Spatial boundary @ land affected by activity

•Need to include periodic loss events (fire, disease,

insects, etc.) in the modeling