Earlier this month, I shared comments regarding the North Carolina’s strategy for addressing the requirements of the Clean Power Plan. In my comments, I recommend an improved strategy to manage the carbon emissions from the generation of electricity in our state that (1) addresses growing concerns over waste management practices, (2) provides additional revenues to existing North Carolina businesses that are organic waste generators; and (3) results in North Carolina power being derived from North Carolina resources. Converting organic wastes, such as food scraps, food processing wastes, animal wastes, and crop residues into biogas (organic recycling) and then using this biogas to fuel existing electricity generating units that are fueled by natural gas is an extremely positive approach to addressing and reducing carbon emissions. North Carolina already has an abundance of organic waste (arguably, our richest resource). In fact, North Carolina has the third greatest potential for biomethane production according to the National Renewable Energy Laboratory (NREL).


Most importantly, emissions from the use of fuels derived from organic waste to generate electricity, also called biogenic carbon emissions us, are considered to be net neutral – meaning, they do not add to atmospheric carbon levels, as the carbon in the fuel is recycled from the atmosphere, rather than mined from deep below the Earth’s surface. The EPA continues to refine and mature its guidance regarding the impacts of biogenic carbon emissions and how fuels derived from organic materials may factor into overall Clean Power Plan compliance. In this developing dialogue, however, it is clear that the harvesting of biogas from organic wastes that may otherwise decompose and emit various GHG’s is a benefit to atmospheric carbon levels.

A copy of the Hearing Officer’s Report (over 13,000 pages) can be obtained here. The comments I submitted in writing, and vocalized at one of the public meetings, were summarized in the Report as follows:

Comment: Gus Simmons of Cavanaugh commented that the conversion of organic waste into biogas, which may easily be refined to renewable natural gas, is an extremely positive approach to addressing carbon emissions. Such organic-waste derived renewable natural gas allows us to continue utilizing existing electricity generating infrastructure (existing power plants that use natural gas to make electricity) and supports the electric utilities continuing to do what they do best – convert fuel into electrons. The final Clean Power Plan rule by EPA recognizes that carbon emissions from the decomposition of organic waste has a net neutral impact on greenhouse gas emissions. Perhaps this is why I see a strategy to addressing the Clean Power Plan so obviously before us – harvest the renewable natural gas potential of our immense organic waste resources, use this Renewable Natural Gas to fuel our energy needs, and buy North Carolina fuel created by North Carolina resources.

The one-line response to my comments was simply put: “The DEQ will consider renewable energy during the development of the backup plan.”

While I am pleased to hear that renewable energy will be considered for the “backup plan”, North Carolina continues to ignore the rich resources in organic-waste derived fuels, right at our fingertips. Certainly there is much more to be gained in addition to reducing the impact to US GHG emissions that North Carolina electricity generation contributes – such as a real, infinitely renewable source of renewable natural gas for electricity generation, manufacturing, and transportation fuels.

More information on biogenic carbon and the role of biomass in achieving Clean Power Plan goals may be obtained in the upcoming EPA Stakeholder Workshop.