NSWMA Comments on Biogenic Sources of Greenhouse Gases

The National Solid Wastes Management Association (NSWMA) recently submitted comments to the United States Environmental Protection Agency (EPA) on how greenhouse gas (GHG) emissions from biogenic sources should be treated under the Prevention of Significant Deterioration (PSD) and Title V Greenhouse Gas Tailoring Rule (generally referred to as the “Tailoring Rule”). NSWMA argued that the GHG produced from biomass should not be regulated in the same manner as anthropogenic GHG (i.e., fossil fuel use) under the Tailoring Rule.

In addition, NSWMA’s comments urged EPA to remain consistent with international, federal, and state protocols involving greenhouse gases and exclude biogenic emissions from the rule. For example, some 33 states and the District of Columbia (DC) have either adopted Renewable Portfolio Standards (20 states and DC) or have voluntary goals (5 states) for adopting renewable energy standards that include landfill gas, biomass, municipal solid waste, and/or anaerobic digestion. NSWMA believes that if biogenic sources and their emissions are not excluded from the Tailoring Rule, it will jeopardize the investment in biogenic energy sources.

Regarding these proposed rules, NSWMA President and CEO Bruce J. Parker stated, “NSWMA believes that EPA should remain consistent with its often repeated policy in regard to the fundamental distinction between biogenic and anthropogenic sources of greenhouse gas emissions and, therefore, exclude biogenic sources from the Tailoring Rule. To do otherwise, simply invites irrational and inconsistent policies and implementations.”

Parker continued, “NSWMA believes that if the Tailoring Rule includes the carbon dioxide produced by biomass, it will overly burden local government and private entities that have invested resources into the development of renewable energy and organics management infrastructure. Imposing the Tailoring Rule permitting requirements to renewable energy projects will discourage future investment in proven technologies for reducing GHGs that utilize waste materials, biomass, and biogas.”

Source : Press Release