1. Tailoring Rule Update BPA / CBEA Joint Annual Meeting February 29, 2012 The Platinum, Las Vegas Gregg Morris Future Resources Associates / Green power Institute

2. Tailoring Rule Timeline 9/30/09: EPA proposes Tailoring Rule for ghgs 6/03/10: Final Tailoring Rule adopted 7/10/10: Call for information on Bioenergy 1/12/11: Intent to defer TR for biogenic C 7/01/11: 3-year deferral granted for biogenic C 9/2011: Accounting framework for biogenic C 10/2011: First public meeting of the SAB 6/1012: SAB report on accounting framework

3. Accounting Framework Introduces Biogenic Accounting Factor: BAF Varies from 0 to 1, can be negative Zero means carbon neutral One means equivalent to fossil C Negative means net reductions, possible offsets Waste and residues have BAF = 0

4. SAB Draft Report Critical of Accounting Framework (AF) simplifications Endorses wastes and residues as carbon neutral Critical of AF temporal and geographic treatment Options: revise BAF, or scrap it entirely –Develop generic BAFs by feedstock type –Require certification as sustainable for C neutrality –Develop a system for granting offsets

5. Lingering Deficiencies While no need to regulate CH 4 from biomass, must include CH 4 in carbon-cycle modeling Should consider dynamic modeling for temporal issues Spatial boundary @ land affected by activity Need to include periodic loss events (fire, disease, insects, etc.) in the modeling