FIA Data and the EPA Accounting Framework for Biogenic CO 2 EMISSIONS

1. FIA Data and the EPA Accounting Framework for Biogenic CO2 EMISSIONS Steve Prisley 2012 National FIA User Group Meeting

2. OVERVIEW • Background: EPA regulating CO2 emissions; different treatment for biogenic CO2? • Proposed accounting framework and role of FIA data • Issues and challenges Photo: 24dash.com

3. 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)

4. Recent EPA actions on biogenic CO2 emissions • EPA, under Clean Air Act, establishes thresholds for stationary sources emitting CO2 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)

5. 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 CO2 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?

6. An accounting framework to adjust biogenic CO2 emissions from stationary sources A unique framework is needed that: • Accounts for a stationary source’s onsite CO2 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

7. 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

8. 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.

9. Defining the scope

10. POTENTIAL Approaches • Use U.S. GHG Inventory as a proxy for national scale assessment of carbon stocks on land: • Biogenic CO2 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 CO2 never contributes to atmospheric load • No assessment of carbon stocks or link to the land • Categorical inclusion: • Biogenic CO2 = fossil CO2 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

11. SELECTED Approach: FEEDSTOCK-BASED • Feedstocks differ in their likely impact on atmospheric CO2: • 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

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

13. 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 anyway • Framework will calculate a Biomass Accounting Factor (BAF) to represent the extent to which these criteria are met.

14. Accounting framework schematic Atmosphere EMISSIONS FROM LAND- USE & MANAGEMENT CHANGES FEEDSTOCK LOSSES DURING TRANSPORT & STORAGE EMISSIONS FROM LEAKAGE DIRECT EMISSIONS FEEDSTOCK GROWTH Stationary Source FEEDSTOCK IN STATIONARY SOURCE FEEDSTOCK NEEDED CARBON CONTAINED IN PRODUCTS AND BYPRODUCTS SEQUESTERED FRACTION Sequestration

15. Accounting framework schematic Atmosphere PGE • L • PRODC SITE - TNC • (1−PRODC) PGE • L • (1−PRODC) PGE • (1+L) • LAR • PRODC+PGE • (1+L) • LAR • (1−PRODC) LEAK •(1−PRODC) PGE • (1−SEQP−PRODC) Stationary Source PGE • (1+L) PGE PGE • PRODC PGE • SEQP Sequestration

16. Framework equation NBE = PGE × (1 + L) × (1 – LAR) × (1 – PRODC) – PGE × SEQP + SITE_TNC × (1 – PRODC) + LEAK × (1 – PRODC) BAF = NBE / PGE NBE: Net Biogenic Emissions PRODC: Product Carbon (%) PGE: Potential Gross Emissions SEQP: Sequestered Proportion LAR: Level of Atmospheric Reduction SITE_TNC: Total Net Change at Site L: Losses in transport/storage Where does FIA fit in?

17. Accounting framework schematic Atmosphere EMISSIONS FROM LAND- USE & MANAGEMENT CHANGES FEEDSTOCK LOSSES DURING TRANSPORT & STORAGE EMISSIONS FROM LEAKAGE DIRECT EMISSIONS FEEDSTOCK GROWTH Stationary Source FEEDSTOCK IN STATIONARY SOURCE FEEDSTOCK NEEDED CARBON CONTAINED IN PRODUCTS AND BYPRODUCTS SEQUESTERED FRACTION Sequestration

18. Accounting framework schematic Atmosphere EMISSIONS FROM LAND- USE & MANAGEMENT CHANGES FEEDSTOCK LOSSES DURING TRANSPORT & STORAGE DIRECT EMISSIONS FEEDSTOCK GROWTH Stationary Source FEEDSTOCK IN STATIONARY SOURCE FEEDSTOCK NEEDED CARBON CONTAINED IN PRODUCTS AND BYPRODUCTS SEQUESTERED FRACTION Sequestration

19. Accounting framework schematic Atmosphere FEEDSTOCK LOSSES DURING TRANSPORT & STORAGE DIRECT EMISSIONS FEEDSTOCK GROWTH Stationary Source FEEDSTOCK IN STATIONARY SOURCE FEEDSTOCK NEEDED CARBON CONTAINED IN PRODUCTS AND BYPRODUCTS SEQUESTERED FRACTION Sequestration

20. Accounting framework schematic Atmosphere DIRECT EMISSIONS FEEDSTOCK GROWTH Stationary Source FEEDSTOCK IN STATIONARY SOURCE FEEDSTOCK NEEDED CARBON CONTAINED IN PRODUCTS AND BYPRODUCTS SEQUESTERED FRACTION Sequestration

21. Accounting framework schematic Atmosphere DIRECT EMISSIONS FEEDSTOCK GROWTH Stationary Source FEEDSTOCK IN STATIONARY SOURCE FEEDSTOCK NEEDED CARBON CONTAINED IN PRODUCTS AND BYPRODUCTS

22. Accounting framework schematic Atmosphere DIRECT EMISSIONS FEEDSTOCK GROWTH Stationary Source FEEDSTOCK IN STATIONARY SOURCE FEEDSTOCK NEEDED Does regrowth balance adjusted emissions?

23. 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

24. 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

25. 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 tCO2e (PGE) • Transport/storage losses negligible (L = 0)

26. CASE STUDY EXAMPLE • Case 1: Source region = New England • Annual sequestration in region: 60,484,044 tCO2e • LAR = 1 (60,484,044 >> 415,800) • BAF = 0 • Case 2: Source region = New Hampshire • Annual sequestration in region: 104,252 tCO2e • LAR = (104,252 / 415,800) = 0.2507 • BAF = 0.7493

27. 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

28. 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

29. 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

30. Technical Issues: baselines? Baselines have been defined in at least three ways: • The net change from a current reference point • Reference point baseline • The net change from a bounded business-as-usual future • Anticipated future baseline • The net change from an alternative future • Comparative baseline • Includes consideration of alternative energy futures

31. Policy issues: time scale? • Should CO2 balances be projected into the future? • Products leaving a stationary source are not counted: should future emissions from them be estimated?

32. 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?

33. 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?

34. Policy ISSUES: Import/Export • Exports impact G/R balance • If no emissions, not in system • Disincentive for domestic renewable energy? Pellet export facility, Eastport, ME Photo: James Lowe

35. Policy ISSUES: Marginal/average • When new plants are permitted, G/R balance changes: what’s fair? • Existing plants grandfathered? • BAF changes for everyone? • Subsequent plants have BAF = 0? Photo: James Lowe

36. 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