catf_filings_biomass_commentsombepaproposedtreatmentbiomasscpp-64f0c45a1e712307.pdf

The document argues that biomass combustion should not be part of the Clean Power Plan's 'best system of emission reduction' because it emits more CO2 per megawatt-hour than coal and relies on speculative, delayed carbon offsets. The authors contend that the EPA lacks a rational scientific framework for biomass carbon accounting and that 'sustainability' standards are an inadequate proxy for carbon dynamics.

• Biomass-based power generation is argued to be unsuitable for the Clean Power Plan's 'best system of emission reduction' (BSER) because it emits approximately 3,000 pounds of CO2 per megawatt-hour, which is about 50% higher than coal-fired power plants.
• The authors assert that biomass combustion cannot be considered part of the BSER because it does not produce immediate CO2 reductions; instead, any net lifecycle reductions depend on carbon offsetting that occurs offsite and in the future, often taking decades or over a century.
• The coalition warns that allowing states to develop their own biomass carbon accounting without EPA guidance would lead to arbitrary results, noting that the EPA's draft Framework for Assessing Biogenic CO2 Emissions from Stationary Sources was criticized by a Science Advisory Board panel and has not been applied to the CPP context.
• The document argues that 'sustainability' standards in forestry cannot serve as a proxy for carbon accounting because they generally do not consider carbon dynamics.

APA

Clean Air Task Force (2015). catf_filings_biomass_commentsombepaproposedtreatmentbiomasscpp-64f0c45a1e712307.pdf. https://cdn.catf.us/wp-content/uploads/2018/09/21094335/CATF_Filings_Biomass_CommentsOMBEPAProposedTreatmentBiomassCPP.pdf

Chicago

Clean Air Task Force. catf_filings_biomass_commentsombepaproposedtreatmentbiomasscpp-64f0c45a1e712307.pdf. 2015. https://cdn.catf.us/wp-content/uploads/2018/09/21094335/CATF_Filings_Biomass_CommentsOMBEPAProposedTreatmentBiomassCPP.pdf.

Wikipedia

{{cite press release |author=Clean Air Task Force |title=catf_filings_biomass_commentsombepaproposedtreatmentbiomasscpp-64f0c45a1e712307.pdf |date=23 June 2015 |url=https://cdn.catf.us/wp-content/uploads/2018/09/21094335/CATF_Filings_Biomass_CommentsOMBEPAProposedTreatmentBiomassCPP.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cleanairtaskforce2015catffilingsbiomasscommentsombepaproposedtreatmentbiomasscpp64f0c45a1e712307pdf, author = {{Clean Air Task Force}}, title = {{catf\_filings\_biomass\_commentsombepaproposedtreatmentbiomasscpp-64f0c45a1e712307.pdf}}, publisher = {Clean Air Task Force}, year = {2015}, month = jun, url = {https://cdn.catf.us/wp-content/uploads/2018/09/21094335/CATF_Filings_Biomass_CommentsOMBEPAProposedTreatmentBiomassCPP.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }