CATF Oral Comments on SAB Review of EPA Biogenic CO2 Accounting Framework (Aug 29, 2017)

The Clean Air Task Force (CATF) critiques the Science Advisory Board's (SAB) draft review of the EPA's biogenic CO2 accounting framework, specifically opposing the use of a 100-year 'emissions horizon' for policy decisions. CATF argues that such a long timeframe is incompatible with the legal and technical capabilities of the EPA and state agencies to enforce regrowth and fossil fuel displacement assumptions. They recommend that the Biogenic Accounting Factor (BAF) be presented as a dynamic, time-dependent curve rather than a single point, allowing regulators to evaluate BAF based on specific policy contexts.

• CATF supports the draft report's assertion that effective biogenic CO2 accounting requires a direct comparison between a policy scenario and an "anticipated baseline" scenario, and encourages the EPA to improve its assessment of emissions from waste-derived feedstocks.
• CATF argues that the draft report's 100-year "emissions horizon" approach is unsuitable for environmental policy because it relies on events taking a century to unfold, which exceeds the legal authority and technical capability of the EPA and state agencies to track or enforce assumptions regarding fossil fuel displacement and regrowth.
• CATF warns that regulators might mistakenly use the 95%-equilibrium value of the cumulative Biogenic Accounting Factor (BAF) at the end of the emissions horizon for short- and medium-term policies, which would be incompatible with the Clean Air Act.
• CATF recommends that the BAF be redefined as a dynamic, time-dependent function represented as a curve over time rather than a single number, allowing the BAF to be evaluated at a specific point on that curve depending on the policy context.

APA

Lewis, J. (2017). CATF Oral Comments on SAB Review of EPA Biogenic CO2 Accounting Framework (Aug 29, 2017). Clean Air Task Force. https://cdn.catf.us/wp-content/uploads/2017/08/21094348/CATF_Testimony_JohnLewis.pdf

Chicago

Lewis, Jonathan. CATF Oral Comments on SAB Review of EPA Biogenic CO2 Accounting Framework (Aug 29, 2017). Clean Air Task Force, 2017. https://cdn.catf.us/wp-content/uploads/2017/08/21094348/CATF_Testimony_JohnLewis.pdf.

Wikipedia

{{cite press release |last1=Lewis |first1=Jonathan |title=CATF Oral Comments on SAB Review of EPA Biogenic CO2 Accounting Framework (Aug 29, 2017) |publisher=Clean Air Task Force |date=29 August 2017 |url=https://cdn.catf.us/wp-content/uploads/2017/08/21094348/CATF_Testimony_JohnLewis.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{lewis2017catf, author = {Lewis, Jonathan}, title = {{CATF Oral Comments on SAB Review of EPA Biogenic CO2 Accounting Framework (Aug 29, 2017)}}, publisher = {Clean Air Task Force}, year = {2017}, month = aug, url = {https://cdn.catf.us/wp-content/uploads/2017/08/21094348/CATF_Testimony_JohnLewis.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }