The Biogenic CO2 Coalition sent a letter to U.S. EPA Administrator Andrew Wheeler on June 9 urging the agency to seek public comments on the regulatory treatment of biogenic CO2 from annual agriculture crops.

The letter references a proposed rule currently under White House Office of Management and Budget review that would classify wood biomass as carbon neutral. “Doing so would be a positive first step towards acknowledging that biogenic emissions are not a net source of greenhouse gas emissions,” the coalition wrote. “But that proposed rule would miss an opportunity to provide the same clarification for an additional category of feedstocks that is just as carbon neutral: annual agricultural crops.”

In the letter, the Biogenic CO2 Coalition said that the bioeconomy is an important, growing source of jobs and economic development in in rural America, but stressed that some “unsound regulatory roadblocks” are holding the sector back. “One such roadblock is EPA’s failure to make clear that processing agricultural crops makes no more than a de minimus contribution to carbon emissions, which results in costly regulatory and permitting requirements that discourage investment,” the coalition continued.

“The science is clear that, like woody biomass, annual agricultural crops are not a net source of carbon emissions,” the coalition wrote. “Indeed, the main relevant difference between woody biomass and annual agricultural crops is that annual crops grow to maturity in a single year—carbon emitted from processing of annual agricultural crops is therefore replaced rapidly when the next year’s crops are grown.  The Department of Agriculture, the IPCC, and various researchers have each recognized that the carbon sequestered by growing agricultural crops cancels out or even outweighs the carbon emitted when those crops are processed.  And EPA has recognized the same in other regulatory programs that rely on the GREET model.”

The letter urges EPA to seek comment in the pending proposed rule on the carbon neutrality of annual crops and on whether facilities that process these annual crops should be exempt from implementing BACT and other requirements of the PSD and Title V programs for the greenhouse gases emitted from the processing of annual crops.

Members of the Biogenic CO2 Coalition include the American Farm Bureau Federation, Corn Refiners Association, National Corn Growers Association, National Cotton Council of America, National Cottonseed Products Association, National Grain and Feed Association, National Oilseed Processors Association, North American Millers’ Association, and Plant Based Products Council.