EPA expects 86 ethanol facilities to be major GHG emitters

By Kris Bevill | October 06, 2009
Report posted Oct. 7, 2009, at 12:41 p.m. CST

The U.S. EPA said 86 U.S. ethanol production facilities will qualify as "major" sources of greenhouse gases (GHGs) and be required to obtain Title V permits if the agency's GHG regulation rule passes as it proposed.

The agency released its proposed rule for the regulation of GHGs on Sept. 30. The Prevention of Significant Deterioration and Title V Greenhouse Gas Tailoring Rule seeks to regulate all industrial facilities that produce more than 25,000 tons per year of carbon dioxide equivalent (CO2e) from stationary combustion sources by subjecting those sources to biannual self-compliance reports and permitting fees. In total, approximately 14,000 major sources of GHG would be required to participate in the permitting process under the EPA's proposed rule. An estimated 400 facilities would be new participants in the permitting program; the remaining 13,661 affected facilities have previously been required to participate in the Title V permitting process through Clean Air Act legislation.

According to technical support documentation from the EPA, the agency estimated the total number of ethanol facilities in the U.S. to be 140 and determined that 61 percent of those facilities emit more than 25,000 tons of CO2e annually. EPM's most recent plant list data, however, shows a total of 183 ethanol facilities currently producing, so it is expected that the number of regulated producers will be more than 86. The EPA also stated in its proposal that its estimations are highly uncertain due to industry growth trends.

Howard Gebhart, environmental compliance section manager at Air Resource Specialists Inc. said it is more likely that nearly all operating ethanol facilities would become regulated entities under the EPA's proposed rule. According to Gebhart, plants as small as 40 MMgy are likely to emit more than 25,000 tons of CO2e annually. (Read "EPA proposes industrial GHG regulations.") According to EPM's plant list, only 38 currently operating U.S. facilities have production capacities less than 40 MMgy.

If the emissions threshold were increased to 100,000 tons of CO2e annually, the EPA estimates that only 43 ethanol facilities would be affected. If the threshold were lowered to 10,000 tons of CO2e, the number of impacted facilities would increase to 94. According to the EPA's proposed rule, the agency set the emissions threshold at 25,000 tons of CO2e because a lower threshold would make the administrative burden unmanageable.

The number of ethanol facilities deemed major sources of GHGs will become clear no later than Jan. 1, when those emitters begin collecting GHG emissions data for the EPA's reporting program. The agency finalized its GHG reporting rule in September and, while it opted to exclude ethanol from its list of source categories, agency spokeswoman Jenny Noonan confirmed that any facility which emits more than 25,000 tons of CO2e from stationary sources will be required to report, including ethanol production facilities.