CPA Submits Comments on Proposed Replacement to Clean Power Plan
CPA submitted comments this week on the Trump Administration’s proposed replacement to the Obama Administration’s Clean Power Plan, known as the Affordable Clean Energy (ACE) rule. CPA’s comments specifically addressed EPA’s request for additional input on:
whether biomass should be included among the list of best system of emission reduction (“BSER”) candidate technologies for states to evaluate when establishing a standard of performance for each affected source in their jurisdiction; and
whether forest-derived biomass should be included as a compliance option for affected units to meet state plan standards under ACE.
CPA strongly urged EPA in both instances to not pursue any policy position under ACE that could lead states to favor the use of wood residuals (e.g., sawdust, shavings, secondary wood chips) for energy use over other existing uses, such as the manufacture of composite wood panels. The comments called for EPA to let market forces govern the price and availability of wood residuals and not to foster policies that would push wood residuals into energy use. In the event EPA decided to incorporate biomass into ACE as BSER or a state compliance option, CPA strongly encouraged EPA to apply the principle of “higher value use” to prioritize reuse and recycling of woody biomass into products such as composite wood panels over burning them for energy. See CPA Comments on ACE Rule. More Info: Jackson Morrill