Biomass Rules, LLC comments to EPA on RFS2
After reviewing and discussing these proposed rules for most of the last nine months, we have submitted our comments to EPA. Basically it came down to a choice that EPA made to focus on setting Renewable Fuel Standards for the four categories set forth in the EISA statute in the manner in which the statute prescribed, or honoring the objective of creating an energy independence by building a market for renewable fuels — which EPA did not choose. I hope now that it is clear that the two can not co-exist as the ESIA and EPA currently stand, that we can move toward two renewable fuel categories with transparent and efficient standards that allow economically driven, energy independence to happen.
Indexing Biomass Benefits and Risks
Many of the regulatory conflicts across agencies, industries, and technologies can be eliminated by indexing critical benefits and risks. This paper discusses the concept and the benefits of adopting this kind of framework in permitting biomass projects
Connecting Spatial Metrics to County-Level DataIndexing Biomass Benefits and Risks
Land-based biomass feedstocks are not equal on a county-level basis. To more accurately reflect the available biomass resources, looking at them on a square mile or square kilometer basis is preferred. County-level data has value, but it must be understood that all counties are not the same size.
The Next Generation Farm Bill: Are Traditional Assumptions Obsolete?
In a word, Yes. Crop production will enhance the environment, energy and income.
Unlocking the benefits of manure regulation
New manure regulations focus on data collection. Value-added energy projects and efficient management require the same kind of records. Farmers must now decide if record keeping costs or pays.
Ruling Blind: Regulation without Information
Environmentalists claim that new technologies shouldn’t be used without long-term research. With little data, markets operate efficiently on transparent regulations and brand loyalty.
Definitive Power: The Policy Impact of Definitions
Conflicts arise on many issues because similar words are defined differently. This paper compares common legal and cultural definitions for similar concepts.
Ineffective, Minus 5 Regulations
Not all regulations operate the same. Some are transparent while others have enormous costs with little benefit. On a scale from 1 to 10, poorly written regulations often score a minus 5.